The introduction of VAT in the United Arab Emirates (“UAE”) on 1 January 2018 is undoubtedly one the biggest exercises for both the governmental and the private sector. While major aspects of the imple- mentation remain unclear (e.g. VAT refund process and duration), one related issue has, so far, not been in the focus of many companies: Through the introduction of VAT, taxable supplies need to be invoiced for tax purposes. By invoicing such transactions, one may document their incompliance with UAE law. The purpose of this newsletter is to give an overview of the legal implications of acting outside the scope existing commercial licenses under the new VAT regime.