Supply chains built on entities without substance are a challenge every VAT system of any size has had to confront. Each administration that has faced the problem has answered the same underlying question — who establishes that a supplier is genuine, and what follows for a buyer who did not establish it? — and the answers form a fascinating spectrum of design choices. Understanding that spectrum is practically useful to a UAE taxpayer preparing for FTA Decision No. 13 of 2026: it shows what a defensible programme looks like where the question has been litigated for decades, and it indicates where compliance environments tend to move as digital infrastructure matures.
What follows is design variety, not evaluation — each route answers a real problem and reflects each administration's context.
The Open Standard: European Union and United Kingdom
The EU and UK route leaves the standard open and fact-specific. Deduction is denied only where the taxpayer knew, or should have known, of a connection to fraud — the principle from the Court of Justice's Kittel line of authority, applied in the UK through Mobilx — and the authority bears the burden of proving it. Neither jurisdiction prescribes a checklist; HMRC has deliberately declined to publish one for two decades, on the reasoning that a definitive list could be satisfied mechanically. The open standard adapts as fraud patterns change; its cost is that an honest trader learns only after the event whether its checks were sufficient.
State Registers and Payment Routes: Poland, Czechia, Slovakia
Poland built public infrastructure: a state-published register of VAT taxpayers — updated daily, queryable by API, carrying bank accounts confirmed through the banking system — with consequences attaching to payment routing, and certainty available through mechanisms such as split payment. Czechia and Slovakia operate structurally similar designs pairing published registers with payment-based routes to certainty. The insight in this family: the state does the verifying, and the buyer's core duty becomes routing payment to the published, verified account.
State Determination, Published as Data: Mexico and Peru
Mexico applies a substance test itself: the tax administration identifies issuers lacking the assets, personnel or capacity for their claimed operations, runs a due-process procedure, and publishes the definitive lists as downloadable open data. Recipients screen against the lists and act within defined windows. Peru arrived independently at a similar architecture. Here the recipient's obligation is essentially responsive — watch the published determinations, and correct where affected.
Recipient Action on the Platform: Brazil, Chile, India
Where e-invoicing platforms mediate every invoice, the recipient's role becomes an act on the platform. Brazil lets recipients register acceptance or rejection events against invoices issued in their name. Chile gives recipients a short statutory window to accept or object, with payment-method safe harbours in defined cases. India conditions input tax credit on the supplier's reported data reaching the recipient's auto-drafted statement, with a management system through which recipients accept, reject or hold each inbound record. The platform carries the verification burden; the recipient exercises judgement through it.
Where the UAE Sits — and Why It's a Coherent Choice
The UAE has specified the measures a taxable person performs itself, with a defined legal consequence for their omission through Article 54 bis of the VAT Law. Compared with the open standard, this gives the honest taxpayer something the EU and UK have never provided: advance certainty about what to do. Compared with the register and platform models, it asks more of the buyer's own organisation — and it arrives just as the UAE's e-invoicing infrastructure begins generating exactly the kind of structured, timestamped supplier data that has elsewhere become the raw material for smarter verification.
That last observation carries the practical lesson of the whole comparison. Across jurisdictions, as digital tax infrastructure matures, verification tends to migrate onto shared rails — published data, machine-readable status, structured invoice flows. A UAE enterprise designing its Decision 13 programme now should build so that manual steps can be replaced by data as data becomes available — rather than hard-wiring a manual process it will later be unable to unwind. How to sequence that, for a specific vendor base and system landscape, is a genuine design question.
How Contiqa Can Help
Contiqa Systems brings this comparative depth to UAE programme design: building verification to a standard that has survived two decades of scrutiny elsewhere, structured to absorb the UAE's maturing data infrastructure instead of fighting it. Contact Contiqa Systems to design a Decision 13 response that will still look well-designed in five years.
Track how UAE businesses are responding to this Decision as it takes effect — visit the Decision 13 Tracker on this site.
This article is general commentary on published legislation and international practice (working from unofficial translations where applicable) and does not constitute tax or legal advice. Obtain advice on your specific circumstances before acting.