Zero-rated exports: 3 documents, 90 days

After the import VAT lesson, we follow goods out of the Kingdom. Short answer: selling goods that leave the Gulf Cooperation Council (GCC) because of the sale is a zero-rated export: the buyer pays no VAT and you still deduct VAT on purchases. But 0% needs proof: within 90 days of the supply you must hold documents showing the goods left the GCC. Without them, the sale is domestic at the standard 15% rate. Here are 4 steps to keep the 0%.

The rule as ZATCA publishes it

Article 32(1) of ZATCA's VAT Implementing Regulations (official Arabic text) requires the supplier to hold evidence, within ninety days of the supply, that the goods left the GCC. ZATCA's imports and exports guideline (2nd edition, May 2026) allows 0% on the supply date if proof is expected in time. During the transitional period, before the GCC electronic services system covers all member states, a sale moving goods to another GCC state counts as an export on the same conditions. ZATCA's published text governs.

Who moves the goods decides their tax treatment

A buyer abroad is not enough: both parties must intend the sale to take the goods out, and who clears and moves them matters:

• Direct export: you arrange shipping out of the GCC and complete the export declaration.
• Indirect export: the customer moves the goods. 0% applies in two cases: you clear customs before ownership passes, or it passes earlier to a non-resident customer obliged to export them, with contract terms confirming they left and were not resold here.
• Domestic sale: a resident customer taking ownership before clearance, even if exporting later, or warehouse collection with no set destination or shipping proof: 15% VAT.

Example: a date factory tracks its shipment on WhatsApp

On 12 October, a Qassim date factory owner writes:

Owner: Invoice a Malaysian company: 400 cartons of Sukkari for 60 thousand riyals, no VAT, it's an export

System: Before issuing, who ships the dates and clears customs, you or the customer?

Owner: The customer; their truck collected them from our warehouse this morning

System: Collection alone does not support 0%; without export proof it is a domestic sale: 9,000 riyals VAT at 15%. Is the customer non-resident, and does the contract oblige them to export, not resell here?

Owner: Yes to both; destination Port Klang, Malaysia

System: Issued a 0% tax invoice in Arabic and English, marked as an export of goods. Still needed by 10 January, 90 days from today's supply: the export declaration and bill of lading. I'll remind you.

Owner (20 November): [export declaration photo]

System (28 December): 13 days left, no bill of lading; ask the customer or shipping line. Without proof by then, ZATCA's guideline requires the standard rate, 9,000 riyals, adjustable once the documents arrive. I'll propose the adjustment for your approval.

Owner (3 January): [bill of lading, destination Port Klang]

System: File complete and stored; the sale stays at 0%.

Invoicing over WhatsApp asks who ships before invoicing and tracks the deadline by date, avoiding audit surprises. Asking for proof early, as in zero-rated vs exempt, is still safer.

4 steps for every export invoice

1. Know who ships before invoicing: delivery terms hint but do not decide; ask who clears, who ships and to where.
2. Issue a tax invoice: Article 53 requires one for goods exports, in Arabic (another language optional), by the 15th of the next month, stating it is a zero-rated export. A simplified invoice is allowed only below 1,000 riyals.
3. Collect 3 documents within 90 days: listed below, tracked by date, not memory.
4. Declare it and deduct its input VAT: exports have their own line in the return, separate from domestic zero-rated sales, per ZATCA's simplified VAT return guide. Article 49 keeps related input VAT deductible, and the imports and exports guideline lets you reclaim any credit when filing.

The three documents and what each proves

This is the Article 32(3) minimum; ZATCA may reject documents that fall short. Keep them at least 6 years from the end of the tax period (Article 66; see record keeping). Services to non-residents have separate conditions under Article 33.