Issue
In accordance with Article 15(3) of Cabinet Decision No. 37 of 2017 on the Executive Regulations of the Federal Decree-Law No. 7 on Excise Tax ("the Executive Regulations"), a warehouse-keeper must submit an application to the FTA in order to register each of the designated zones over which it is responsible. As part of this process, the FTA requires the warehouse-keeper to pay a registration fee in order to register the designated zone for a period of 12 months.
This means that every 12 months, warehouse- keepers must apply to renew the registration of their designated zones in order to maintain their status. If a designated zone does not have its registration renewed in accordance with FTA's procedures, it will cease to be considered a designated zone for Excise Tax purposes and Excise Tax will be immediately imposed on the excise goods held within.
Summary
Each Excise Tax warehouse-keeper must take the following actions:
Review the registration expiry dates of its designated zones;
Submit the designated zone renewal (amendment) form and pay the renewal fee separately for each designated zone requiring renewal;
Review the value and type of excise goods held in the designated zone so that the FTA may review the value of the current financial guarantee and instruct the warehouse-keeper to lodge an updated financial guarantee if required.
In the event that the above process is not followed and the designated zone registration is not renewed, all excise goods held within the designated zone on the date of the registration expiry will be considered to be released for consumption in the UAE. Excise Tax shall, therefore, become payable on those goods immediately.
Detailed discussion
Renewal form
In order to renew a designated zone's registration, in order for it to continue to maintain its 'designated zone' status for Excise Tax purposes, the warehouse keeper responsible for that designated zone must submit an amendment form for renewal purposes to the FTA.
The renewal form shall be available to be filed 30 days before the expiry date of the designated zone registration. The warehouse keeper will receive an e-mail notification of its requirement to renew the registration of the designated zone it is responsible for during this period.