UAE excise tax registrants must maintain and provide to the Federal Tax Authority price lists of all excise goods they produce, import, or sell, and keep comprehensive tax records under Articles 23 and 24 of Federal Decree-Law No. 7 of 2017 and Article 23 of Cabinet Decision No. 37 of 2017. The Tax Registration Number (TRN) must be stated on all correspondence and dealings with the FTA. Failure to maintain records attracts penalties of AED 10,000 (first violation) and AED 20,000 (repeat within 24 months). Abdelhamid & Co (FTA TAAN 20033908) provides compliance review services covering excise tax record-keeping adequacy and price list management.
Price List Obligations Under Article 23 of the Executive Regulation
Article 23(1) of the Executive Regulation (Cabinet Decision No. 37 of 2017, amended by Cabinet Decision No. 108 of 2023) requires every taxable person to retain price lists of excise goods produced, imported, and sold, and to provide such records to the FTA upon request. Article 23(2) specifies that the price lists must be sufficient to identify the excise goods produced, imported, or sold and must include details of their values. This is not merely a requirement to have a general price list — it must be specific enough for the FTA to identify each excise good and its associated values.
The penalty for failure to provide the FTA with price lists of excise goods is AED 5,000 for the first time and AED 10,000 for repeat violations, under Table 2 of Cabinet Decision No. 40 of 2017. This penalty is separate from the general record-keeping failure penalty, specifically targeting the price list obligation that is unique to excise tax (as opposed to the general record-keeping requirements that apply to both VAT and excise).
Comprehensive Tax Record Requirements — Article 24 of the Decree-Law
Article 24(1) of Federal Decree-Law No. 7 of 2017 requires taxable persons to keep the following specific records:
- Records of all produced, imported, or stockpiled excise goods
- Records of exported excise goods and evidence of such export
- Records of stock levels, including details of lost or destroyed items
- A Tax Record containing: due tax on imported excise goods; due tax on produced excise goods; due tax on stockpiled excise goods; and deductible tax under Article 16 of the Decree-Law
The requirement to record stock levels, including lost or destroyed items, is particularly important for Designated Zone operators. FTA Decision No. 6 of 2025 (effective 1 July 2025) requires Warehouse Keepers to document natural shortage with Reports from approved Independent Competent Entities, and such documentation forms part of the required records for any destroyed or deficient items in the zone.
Record Retention Periods and Controls
Under Article 23(3) of the Executive Regulation, required tax records must be kept in accordance with the timeframes, controls and conditions provided for in the Executive Regulation of the Tax Procedures Law (Federal Decree-Law No. 28 of 2022, implemented through Cabinet Decision No. 74 of 2023). In practice, the standard record retention period is five years from the end of the relevant tax period — a period that aligns with the FTA's standard audit window. For excise goods with ongoing compliance issues or disputed valuations, longer retention may be prudent.
Article 24(3) of the Decree-Law confirms that the Executive Regulation specifies the timeframes, conditions, and controls for retention of the specific records listed in Article 24(1). Records must be available for FTA inspection during a tax audit — failure to produce records during an audit constitutes a separate violation under the Tax Procedures Law, attracting additional penalties.
Marking of Excise Goods — Physical Tax Payment Evidence
Article 24(2) of the Decree-Law authorises the Cabinet, at the suggestion of the Minister of Finance, to specify which excise goods must bear marks indicating that tax has been paid. Tobacco products have been subject to a digital tax stamp (DTS) marking scheme since the excise tax regime began in 2017. These marks serve as physical evidence of excise tax payment and are inspected at customs and retail checkpoints. Goods bearing counterfeit or invalid marks are treated as a tax evasion indicator under Article 23 of the Decree-Law.
Tax Registration Number (TRN) Display Obligation
Article 25 of the Decree-Law requires the taxable person, or any person authorised in writing by the taxable person, to state their Tax Registration Number on all correspondence and dealings with the FTA, all tax returns, and any document related to tax. This is a straightforward but frequently overlooked compliance obligation — internal documents, FTA portal submissions, price lists submitted to the FTA, voluntary disclosures, reconsideration request letters, and any other communication with the FTA must carry the TRN.
Record-Keeping Penalty Schedule
| Violation | Penalty (AED) | Authority |
|---|---|---|
| Failure to keep required records (general) | 10,000 first; 20,000 repeat in 24 months | Table 1, CD 40/2017 |
| Failure to submit records in Arabic when requested | 5,000 | Table 1, CD 40/2017 |
| Failure to provide price lists of excise goods | 5,000 first; 10,000 repeat | Table 2, CD 40/2017 |
| Failure to facilitate tax auditor access to records | 20,000 | Table 1, CD 40/2017 |
| Submitting false documents or records | Criminal (Tax Evasion) — Tax Procedures Law | Art. 23, Decree-Law 7/2017 |
Arabic Language Requirement for Records
Under Table 1 of Cabinet Decision No. 40 of 2017, failure to submit required data, records, and documents related to tax in Arabic to the FTA when requested attracts a penalty of AED 5,000. While records may be maintained in English or other languages, the taxable person must be able to produce Arabic-language versions of records when the FTA specifically requests them. Businesses operating in the UAE with records solely in foreign languages should factor in the cost and lead time of translation when assessing their compliance position.
Why Choose Abdelhamid & Co for Excise Tax Record-Keeping Compliance
Our compliance review service assesses the completeness and adequacy of excise tax records against the specific requirements of Article 24 of the Decree-Law and Article 23 of the Executive Regulation. We identify gaps before FTA audit exposure and establish record systems that satisfy both the FTA's price list requirements and the detailed stock-level tracking obligations. Our data analytics team can assist with automating excise good tracking for businesses with large product portfolios.
Frequently Asked Questions
What records must a UAE excise tax registrant keep under Article 24 of the Decree-Law?
Under Article 24(1) of Federal Decree-Law No. 7 of 2017, the required records include: records of all produced, imported, or stockpiled excise goods; records of exported goods and export evidence; stock level records including lost or destroyed items; and a tax record capturing due tax on imports, productions, and stockpiled goods, plus deductible tax amounts.
What is the penalty for not providing price lists to the FTA for excise goods?
Under Table 2 of Cabinet Decision No. 40 of 2017, failure to provide the FTA with price lists of excise goods produced, imported, or sold attracts a penalty of AED 5,000 for the first violation and AED 10,000 for repeat violations. This is a separate penalty from the general record-keeping failure penalty.
How long must UAE excise tax records be retained?
Under Article 23(3) of Cabinet Decision No. 37 of 2017, records must be retained per the timeframes in the Tax Procedures Law Executive Regulation — in practice, five years from the end of the relevant tax period. This aligns with the FTA's standard audit window and should be treated as the minimum retention period.
Must UAE excise tax records be maintained in Arabic?
Not necessarily during normal operations, but when the FTA requests records in Arabic, they must be provided. Under Table 1 of Cabinet Decision No. 40 of 2017, failure to submit required records in Arabic when specifically requested by the FTA attracts a penalty of AED 5,000. Businesses with records solely in foreign languages should ensure Arabic translation capability is available.
Where must a UAE excise taxable person display their TRN?
Under Article 25 of Federal Decree-Law No. 7 of 2017, the TRN must be stated on all correspondence and dealings with the FTA, all tax returns, and any document related to tax. This applies to the taxable person or any person authorised in writing to represent them — including tax agents and legal representatives.
Related Services
- Compliance Review — audit record-keeping adequacy before FTA inspection
- Tax Agency Service — authorised tax agent for FTA correspondence and submissions
- External Audit — independent audit of excise tax compliance records
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