UAE sets reverse charge rules for metal scrap trades

Ministry of Finance has announced Cabinet Decision No. 153 of 2025, setting out the application of the reverse charge mechanism on the trading of metal scrap between VAT-registered businesses in the UAE, with the framework scheduled to take effect on 14 January 2026. The move is positioned as a targeted adjustment to the country’s value-added tax regime, aimed at strengthening compliance and reducing tax leakage in a sector long regarded by authorities as vulnerable to misreporting and cash-based transactions.

The decision has been issued under the provisions of Federal Decree Law No. 8 of 2017 on Value Added Tax, along with its subsequent amendments, and Cabinet Resolution No. 52 of 2017 covering the Executive Regulations of the VAT law. Together, these instruments provide the legal basis for shifting VAT liability from the supplier to the recipient in specified transactions, a mechanism already familiar to many businesses operating in regulated or high-risk supply chains.

Under the reverse charge mechanism, the obligation to account for VAT on a transaction moves from the seller to the buyer, provided both parties are registered for VAT. In the context of metal scrap trading, this means suppliers will issue tax invoices without charging VAT, while purchasers will self-account for the tax in their VAT returns, subject to the normal rules on input tax recovery. Officials say the approach is designed to curb evasion practices that can arise where VAT is charged but not remitted to the tax authority.

The Ministry of Finance has framed the decision as part of a broader effort to fine-tune the VAT system since its introduction in 2018, responding to sector-specific risks identified through audits and market monitoring. Metal scrap trading, which often involves multiple intermediaries and fluctuating commodity prices, has been highlighted in several jurisdictions worldwide as an area where reverse charge measures can enhance transparency and simplify enforcement.

The cabinet decision on scrap VAT treatment reflects a policy choice already adopted in parts of Europe and Asia, where tax authorities have used reverse charge rules to counter carousel fraud and other forms of abuse linked to recyclable materials and metals. By aligning with these international practices, the UAE is seeking to balance ease of doing business with the need for robust revenue protection.

Industry participants are now assessing how the change will affect cash flow and contractual arrangements. For suppliers, the removal of VAT charging on eligible scrap transactions may reduce administrative burdens and the need to finance VAT amounts pending recovery. Buyers, on the other hand, will need to ensure their accounting systems can correctly self-assess VAT and reflect the entries accurately in periodic returns. Tax advisers note that while the mechanism is neutral in theory for fully compliant, fully taxable businesses, errors in classification or documentation could lead to penalties.

The decision applies specifically to transactions between registrants, underscoring the importance of verifying counterparties’ VAT registration status. Businesses involved in mixed supplies, or dealing with unregistered parties, will need to distinguish carefully between transactions subject to the reverse charge and those that remain under the standard VAT rules. This distinction is expected to be a focal point of guidance and compliance reviews ahead of the January 2026 effective date.

Officials have indicated that further clarification will be issued through administrative guidance to define the scope of “metal scrap” covered by the decision, drawing on existing definitions used in customs and commercial practice. Market participants expect this to include waste and scrap from metals such as iron, steel, aluminium and copper, though the final interpretation will determine how widely the measure applies across recycling and manufacturing chains.

The timing of the announcement gives businesses more than a year to prepare, adjust contracts and update systems. Tax specialists view this lead time as significant, allowing companies to conduct impact assessments and staff training without disrupting ongoing operations. It also provides an opportunity for the authorities to engage with industry bodies and address practical concerns before enforcement begins.