Yes. Once your business has a Tax Registration Number (TRN), the Federal Tax Authority (FTA) expects a VAT return for every tax period, whether you sold anything or not.
A nil return takes a few minutes on EmaraTax. Missing one costs AED 1,000, and AED 2,000 if it happens again within 24 months.
The Short Answer: Registration Creates the Obligation
The duty to file comes from being registered, not from making sales. Article 72 of the VAT law requires a return for each tax period. The FTA's VAT returns user guide is explicit that a registrant with nothing to report must still submit a nil return by the due date.
The obligation runs until the FTA approves your deregistration. It doesn't end when sales stop, when the business goes quiet or when you apply to deregister.
When Is a Nil VAT Return Due?
The return and any payment are due by the 28th day after the end of the tax period. Most businesses file quarterly. Businesses with turnover of AED 150 million or more file monthly, and the FTA can assign other periods (u.ae).
VAT quarters are assigned by the FTA and don't always match calendar quarters, so check your period dates on EmaraTax.
If the 28th falls on a weekend or public holiday, the deadline moves to the next working day, as the FTA's filing guidance explains. For periods ending 31 October 2026, the 28th is a Saturday, so the return is due on Monday 30 November 2026.
What Can a "No Sales" Return Still Contain?
A return with no sales isn't always a return full of zeros. Check these entries before you submit.
| Return Entry | What Goes In It | Why a No-Sales Business Might Have It |
|---|---|---|
| Box 9 | Standard-rated expenses and recoverable input VAT | Rent, fit-out, professional fees and other set-up costs |
| Box 6 | Goods imported into the UAE | Pre-filled from customs data when you import stock or equipment |
| Boxes 3 and 10 | Supplies subject to the reverse charge | Overseas software, cloud services and online ads |
| Box 7 | Adjustments to imported goods | Corrections to customs-reported imports |
| Error Corrections | Earlier-period errors with a tax difference of AED 10,000 or less | Fixing a small mistake without a voluntary disclosure |
The reverse charge is the entry most easily missed in a quiet period. If you pay for software or advertising from overseas suppliers, you report it even when you have no sales; see Do UAE Businesses Pay VAT on Overseas Software Subscriptions?
Can You Recover Input VAT Before Your First Sale?
In most cases, yes. Input VAT is recoverable on costs used, or intended to be used, for taxable supplies (Article 54). A business preparing to trade can therefore claim VAT on its set-up costs, as long as it holds valid tax invoices.
That often leaves a pre-trading business with more input VAT than output VAT. You can carry the excess forward, or request a refund by ticking Box 15 and then filing form VAT311.
Two time limits apply from 2026:
- An excess credit carried forward lapses five years after the end of the period it arose in (Article 74, as amended from 1 January 2026).
- Refund requests must be made within five years (Ministry of Finance).
A transitional window covers older credits. Where the five years ended before 1 January 2026, or end within a year of it, the credit can still be claimed by 31 December 2026. If you've carried a credit for years, check it now; VAT refunds support covers the claim.
How to File a Nil VAT Return on EmaraTax
- Log in to EmaraTax with UAE Pass or your account details.
- Open your VAT registration and select the return for the tax period.
- Check any pre-filled import figures against your customs declarations.
- Enter expenses, reverse-charge purchases and corrections, and leave everything else at zero.
- Review the totals, tick the declaration and submit.
- Download the acknowledgement and keep it with that period's records.
The FTA's submit and pay guide and EmaraTax videos show each screen. If any VAT is payable, pay it by the same deadline through GIBAN or MagnatiPay.
What Happens If You Don't File?
These are the penalties in Cabinet Decision No. 40 of 2017, as amended by Cabinet Decision No. 129 of 2025 from 14 April 2026.
| What Went Wrong | Penalty |
|---|---|
| Return filed late | AED 1,000; AED 2,000 for a repeat within 24 months |
| Tax paid late | 14% a year, charged for each month or part month from the day after the due date |
| Incorrect return | AED 500, unless corrected before the filing deadline |
| Deregistration applied for late | AED 1,000, charged again each month, up to AED 10,000 |
A nil return with no tax due can't attract the late payment penalty, but the late filing penalty still applies. Missing four quarterly filings could result in penalties of up to AED 7,000: AED 1,000 for the first and AED 2,000 for each repeat within 24 months.
The FTA can also raise an assessment for periods with no return. If you think a penalty was wrongly imposed, you can ask the FTA to look again through a reconsideration request; VAT fines support covers the process.
Should You Deregister Instead?
You must apply to deregister if the business has stopped making taxable supplies (Article 21 of the VAT law). The same applies if taxable supplies over the last 12 months were below AED 187,500 and you don't expect to exceed that in the next 30 days. Article 14 of the Executive Regulation gives 20 business days to apply, while the FTA's deregistration page currently says 30, so work to the shorter deadline. Applying late costs AED 1,000 a month, up to AED 10,000.
You may also choose to deregister if supplies over 12 months are below AED 375,000 (Article 22). A business that registered voluntarily can't deregister in its first 12 months (Article 23).
Keep filing until the FTA approves the application. You'll file a final return and pay any tax and penalties due, because deregistration doesn't cancel amounts owed. The FTA can also deregister a business itself.
The FTA's VAT deregistration service lists the documents, and our VAT deregistration team can manage the application. If the company is closing altogether, Corporate Tax needs its own deregistration.
What If You Only Make Zero-Rated Supplies?
A business whose supplies are all zero-rated, such as exports, can ask the FTA for an exception from registration (Article 15). With an approved exception, it doesn't file periodic returns. Our post on VAT Exemption Versus Exception explains the conditions.
Common Mistakes
Skipping the Return Because Nothing Was Sold
The return is due because you are registered. A period with no sales still needs a submission by the deadline.
Filing Zeros When There Were Overseas Purchases
Software, cloud services and advertising expenses subject to the reverse charge mechanism must be reported in Boxes 3 and 10 in every VAT return period. Omitting these transactions results in an inaccurate VAT return, even where the net VAT impact is nil.
Leaving an Excess Credit Untouched
Credits now lapse after five years. Older credits caught by the transitional rule must be claimed by 31 December 2026.
Stopping Returns After Applying to Deregister
Submitting a deregistration application does not constitute approval. VAT returns must continue to be filed until the FTA officially confirms the effective deregistration date.
Not Keeping the Evidence Behind a Nil Return
Keep bank statements and invoices for every period, including quiet ones. Our guide to organising VAT paperwork covers retention periods.
How A&A Can Help With Quiet Periods
We prepare and file nil and low-activity returns, check imports and reverse-charge entries, and track any excess credit so it doesn't lapse. If the business has stopped trading, we handle the deregistration and the final return.
See our VAT return filing and VAT services pages, or ask us to take over your VAT filings.
File the Quiet Periods on Time
A nil VAT return is the simplest compliance task a registered business has. Check imports, reverse-charge purchases and credits before you submit. If the business has stopped trading, deregister rather than filing zeros indefinitely.
Frequently Asked Questions
What Is a Nil VAT Return in the UAE?
It is a VAT return for a tax period in which you have nothing to report, submitted on EmaraTax by the normal deadline. Every box may show zero, but the return is still required.
What Is the Penalty for Not Filing a Nil VAT Return?
AED 1,000 for the first late return and AED 2,000 for each repeat within 24 months. No late payment penalty applies when no tax is due.
Can I Stop Filing VAT Returns If My Business Is Dormant?
Not while you're registered. Apply to deregister if you've stopped making taxable supplies, and keep filing until the FTA approves it.
Do I File a VAT Return If I Haven't Started Trading Yet?
Yes. A return is due for each tax period from registration, sales or not. The first one is often where you recover VAT on set-up costs.
Can I Claim Input VAT If I Made No Sales?
Usually, yes, if the costs relate to taxable supplies you make or intend to make and you hold valid tax invoices.
What Happens to Excess Input VAT on a Nil Return?
You can carry it forward, or request a refund through Box 15 and form VAT311. A credit carried forward now lapses five years after the end of the period it arose in.
Is a Nil VAT Return the Same as a Nil Corporate Tax Return?
No. They are separate obligations with different deadlines.
I Missed Several Nil Returns. What Should I Do?
File every overdue return now, oldest first. Each late return carries its fixed penalty, but leaving them unfiled invites assessments and blocks deregistration.