How to Handle B2B Customers Outside Saudi Arabia (e.g., Abu Dhabi)

XML and business rules
1

@Ankit_Tiwari @idaoud
We are currently integrating ZATCA e-invoicing and facing an issue while issuing a B2B invoice to a standard customer based in Abu Dhabi (UAE). Since the customer is not located in Saudi Arabia, their VAT registration number is not in the Saudi format.

:warning: Important Note: This invoice is subject to 15% VAT because it is not considered an export invoice under Saudi VAT rules.

When we try to connect the invoice using the Clearance API, we receive the following error:

“The buyer VAT registration number or buyer group VAT registration number (BT-48) must contain 15 digits. The first digit and the last digit must be “3”.”

We have a few questions regarding this situation:

  1. Should we issue this as a simplified invoice?
    Can we use the <cbc:InvoiceTypeCode name="0200000">388</cbc:InvoiceTypeCode> and treat it as a simplified invoice, even though it’s technically B2B, since the buyer is not registered under Saudi VAT?
  2. Can we skip the buyer’s address in this case?
    As this is a standard customer from outside KSA, is it acceptable to skip address fields like country, region, and postal code?
  3. Or should it still be connected as a standard invoice?
    If yes, should we use <cbc:InvoiceTypeCode name="0100000">388</cbc:InvoiceTypeCode> and is there a way to handle the foreign VAT number without violating ZATCA’s BT-48 requirement?

We would appreciate guidance on the correct invoice type code and data structure to be used for foreign B2B buyers in compliance with ZATCA regulations, especially in cases where the invoice is taxable at 15% VAT.

2

@arjun_tech24 include UAE VAT Number of the Buyer under the field “Other Buyer ID (BT-46)” with attribute “OTH”. Do not include foreign VAT number in the field Buyer VAT Registration Number (BT-48) as this is dedicated only to KSA VAT Number.

3

Hi @Ankit_Tiwari :waving_hand:

Thank you so much for your clarification! Based on your guidance, we’ve now included the UAE VAT number of the buyer under the “Other Buyer ID (BT-46)” with the attribute OTH and excluded it from “Buyer VAT Registration Number (BT-48)” as it’s only meant for KSA VAT numbers.

Can you please confirm if the following XML snippet is correct?

<cac:AccountingCustomerParty>
    <cac:Party>
        <cac:PartyIdentification>
            <cbc:ID schemeID="OTH">100111111100003</cbc:ID>
        </cac:PartyIdentification>
        <cac:PostalAddress>
            <cbc:StreetName>Test street</cbc:StreetName>
            <cbc:BuildingNumber>1111</cbc:BuildingNumber>
            <cbc:CitySubdivisionName>ABUDHABI</cbc:CitySubdivisionName>
            <cbc:CityName>Ras Al Khaimah</cbc:CityName>
            <cbc:PostalZone>85631</cbc:PostalZone>
            <cac:Country>
                <cbc:IdentificationCode>AE</cbc:IdentificationCode>
            </cac:Country>
        </cac:PostalAddress>
        <cac:PartyLegalEntity>
            <cbc:RegistrationName>ABC Services Group FZ-LLC</cbc:RegistrationName>
        </cac:PartyLegalEntity>
    </cac:Party>
</cac:AccountingCustomerParty>

Also, just to double-check — since this is a standard B2B invoice, we are using the following invoice type code:

<cbc:InvoiceTypeCode name="0100000">388</cbc:InvoiceTypeCode>

Is this the correct choice for this scenario (foreign B2B customer with 15% VAT)? Your confirmation would be really helpful :folded_hands:

Thanks again!

4

@Ankit_Tiwari
Can you please confirm if the above XML snippet is correct?