How to Invoice a Developer for Real Estate Commission in the UAE

Quick answers

Do I charge VAT on commission I invoice a developer?

Yes, 5%, if your agency is VAT registered. Estate agents' services are a service of their own, so the 5% applies even when the unit itself is zero-rated (the first sale of a new home) or exempt (a resale).

What kind of invoice does the developer need?

A full tax invoice: the words "Tax Invoice", your name, address and TRN, the developer's name, address and TRN, a sequential number, the issue date, the date of supply if different, a description, and the amount, VAT and total in AED.

What is the VAT on 2% commission on a AED 1,850,000 sale?

The commission is AED 37,000, the VAT at 5% is AED 1,850, and the developer pays AED 38,850.

What must a commission invoice to a developer include?

Every particular of a full tax invoice, because the developer is VAT registered and a commission above AED 10,000 to a registered customer cannot go on a simplified one (Executive Regulation, Article 59(1) and (5)). On a commission invoice that means:

• The words "Tax Invoice", clearly displayed (Art. 59(1)(a))
• Your agency's name, address and TRN (Art. 59(1)(b))
• The developer's name, address and TRN (the developer is VAT registered) (Art. 59(1)(c))
• A sequential or unique invoice number that shows its place in your sequence (Art. 59(1)(d))
• The date of issue (Art. 59(1)(e))
• The date of supply, if it differs from the issue date (see the off-plan section below) (Art. 59(1)(f))
• A description of the service: sales commission, with the project, the unit, the developer's deal reference and the basis, such as 2% of the sale price (Art. 59(1)(g))
• For the line: unit price, quantity (1 for a single commission), the VAT rate (5%) and the amount payable in AED (Art. 59(1)(h))
• The amount of any discount offered (Art. 59(1)(i))
• The gross amount payable in AED (Art. 59(1)(j))
• The VAT in AED, with the exchange rate if you invoice in another currency (Art. 59(1)(k))

The law asks for a description of the service; it does not list the unit or the deal reference as separate fields. They are what make the description usable: the developer's finance team matches your invoice to the sale by them, and a vague "commission" line is the one that comes back. The general rules are in how to create a VAT invoice in the UAE and tax invoice vs simplified tax invoice.

Commission invoices to developers are business-to-business, so they move to e-invoicing once it applies to you: from 1 July 2027 for businesses with revenue under AED 50 million. See the UAE e-invoicing timeline.

Is VAT charged on real estate commission?

Yes. Commission is charged at the standard 5% rate, whatever the VAT treatment of the property you sold. The standard rate applies to every taxable supply (Decree-Law, Article 3), and the zero-rated and exempt lists cover the property itself, not the agent's service:

• New residential unit, first sale within three years of completion: zero-rated for the developer (Article 45(9)). Your commission: 5%.
• Residential resale or residential lease: exempt (Article 46(2)). Your commission: 5%.
• Bare land: exempt (Article 46(3)). Your commission: 5%.
• Commercial property: 5%. Your commission: 5%.

The FTA's own guide confirms it from the other side: when a resale is exempt, the VAT the seller pays on agent fees is VAT it cannot recover (FTA Real Estate VAT Guide, section 3.3). The VAT is on your invoice either way; whether your customer can reclaim it is their side.

Not registered yet? Then you invoice without VAT until you are. Commission counts towards the registration threshold; see do I need to register for VAT?

Off-plan sales: who do you invoice and when?

You invoice whoever owes you the commission under your agreement, which on an off-plan sale paid by the developer is the developer, within 14 days of the date of supply (Decree-Law, Article 67(1)). The tax invoice goes to the recipient of your service, so if the developer pays you, the developer's name, address and TRN go on it, not the buyer's.

For a service, the date of supply is the earliest of three events (Article 25(6) and (7)):

• the day your service is completed;
• the day you receive payment;
• the day you issue the tax invoice.

The law does not say which event completes a broker's service on an off-plan sale. That follows from your agreement with the developer, for example commission earned when the buyer signs the sale and purchase agreement and pays the first instalment. Read the agreement, and if it is unclear, ask the developer or a tax advisor rather than guessing.

Two cases change the timing. If the developer pays part of the commission first, VAT is due on the amount paid when you receive it (Executive Regulation, Article 19; see VAT on advance payments). If the agreement pays the commission in instalments or by consecutive invoices, the date of supply is the earliest of the invoice date, the due date on the invoice, the payment date, or one year after the service (Decree-Law, Article 26(1)).

Missing the 14 days costs AED 2,500 for each case of a tax invoice not issued in time (Cabinet Decision No. 40 of 2017 as amended by No. 129 of 2025, Table 3 item 4, from 14 April 2026).

What does a commission invoice look like? A worked example

Mangrove Key Realty LLC sold an off-plan unit in Lumen Crescent, Tower A, Unit 1407, for AED 1,850,000. Its agreement with Lumen Crescent Developments LLC pays 2% of the sale price, earned when the buyer signs and pays the first instalment, which happened on 3 November 2026. The names, TRNs and project are invented.

The dates that follow from it:

• Invoice deadline: 17 November 2026, 14 days after the date of supply. Issued on 5 November 2026, it is in time.
• VAT return: the agency files quarterly, so the AED 1,850 goes in the period ending 31 December 2026, with the return and payment due by 28 January 2027, whether or not the developer has paid by then. Check your own period with the VAT return deadline calculator.

Buyer or developer outside the UAE: still 5%?

Yes, for property in the UAE. Estate agents' services are services directly connected with real estate (Executive Regulation, Article 21(3)(d)), and their place of supply is where the property is (Decree-Law, Article 30(7); FTA Real Estate VAT Guide, section 11.2).

The zero rate for exported services does not help either: it excludes services supplied directly in connection with real estate in the UAE (Executive Regulation, Article 31(1)(a)(2)). So a buyer in London or a landlord in Mumbai pays 5% on your commission, the same as a customer in Dubai.

You can still invoice in USD or another currency, as long as the VAT is shown in AED with the exchange rate (Article 59(1)(k)); see invoicing in USD instead of AED.

Co-broke: how is the commission invoiced when two agencies share it?

Each agency invoices only its own share, to whoever pays it that share, with 5% VAT if it is registered. FTA guidance does not deal with co-broke splits as such, so this follows from the general rules: each agency makes its own supply and issues its own tax invoice for it.

• The developer pays each agency directly: each agency invoices the developer for its share.
• The developer pays one agency in full and it passes on a share: the lead agency invoices the developer for the full commission, and the co-broker invoices the lead agency for its share. For the lead agency that is a cost of a taxable supply, so it can normally recover the VAT on it (Decree-Law, Article 54).

What goes wrong is the same share invoiced twice, once to the developer and again to the other agency. Put the split in writing before the deal closes, so each side knows whom it invoices.

Rental deals: is there VAT on commission from a landlord or tenant?

Yes, 5%, even though a residential lease itself is exempt (Decree-Law, Article 46(2)). Invoice whoever pays the commission, landlord or tenant. A tenant who is a private person is not VAT registered, so a simplified tax invoice is allowed at any amount, though a full one is always fine (Executive Regulation, Article 59(5)). A company tenant or landlord with a TRN gets a full tax invoice above AED 10,000.

Frequently asked questions