Article 10 of Ministerial Decision No. 243 of 2025 is brief — two clauses — but it defines the most significant governance dimension of the UAE Electronic Invoicing System: the Federal Tax Authority's data access and sharing powers. Every invoice transmitted through the system becomes accessible to the FTA in real time. Article 10 is the statutory basis for that access, and for the onward sharing of that data with other government bodies and foreign authorities.
Clause 1: Real-Time FTA Access
Article 10(1): "The Authority shall have the power to access and use any data processed, received and stored under the Electronic Invoicing System."
The scope of this access power is total. The FTA may access "any data" — not a defined subset, not data for specific taxpayers under audit, not data requested through a formal information notice. All data processed, received, and stored under the Electronic Invoicing System is accessible to the FTA as a matter of course. In the PINT-AE architecture, this access is realised through Corner 5 — the FTA's reporting interface — which receives invoice-level data at the point of exchange. The FTA does not need to audit a taxpayer to see that taxpayer's invoice data. It receives that data continuously from the moment the system is operational.
The practical consequence is a fundamental shift in the information asymmetry between the FTA and taxpayers. Under the pre-e-invoicing model, the FTA's visibility into transaction-level data depended on VAT returns filed quarterly and audit enquiries made periodically. Under the Electronic Invoicing System, the FTA has invoice-level visibility across the entire in-scope business population in near real time. The VAT return continues to exist — but the FTA can now compare it against the underlying invoice data it has already received before the return is filed.
For tax directors and finance teams, this changes the risk calculus for several practices that currently exist in a gap between what the VAT return shows and what the underlying transactions support: rounding at the invoice level, selective credit note issuance, aggressive VAT treatment of borderline supplies, and delayed output VAT reporting. Where the VAT return and the electronic invoice data diverge, the FTA does not need an audit trigger to detect the divergence.
Clause 2: Cross-Government and International Data Sharing
Article 10(2): "Subject to the terms and conditions stipulated in the Tax Procedures Law and its executive regulations, the Authority shall have the power to share any data processed, received and stored under the Electronic Invoicing System with other Government Entities or foreign government bodies pursuant to the implementation of the obligations of the State under any international agreement, treaty or arrangement to which the State is a party."
Two categories of data sharing are authorised: domestic cross-government sharing, and international sharing under treaty or agreement.
Cross-Government Sharing
The FTA may share electronic invoice data with other UAE government entities — without specifying which entities or under what circumstances — subject to the Tax Procedures Law framework. The Ministry of Economy, the UAE Central Bank, the Statistics Centre, and customs authorities are all Government Entities under the Article 1 definition. The potential for electronic invoice data to be used in economic analysis, financial sector supervision, trade statistics, and customs intelligence is significant. For businesses that currently treat invoice data as confidential commercial information visible only to the FTA, the Article 10(2) cross-government sharing power represents a material expansion of the government audience for that data.
International Sharing Under Treaty
The UAE is party to numerous international tax cooperation agreements: the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAC), bilateral tax information exchange agreements, and the Common Reporting Standard framework under the OECD. Article 10(2) authorises the FTA to share electronic invoice data with foreign government bodies under any of these international arrangements. For multinationals operating in the UAE, this means that electronic invoice data transmitted through the UAE Electronic Invoicing System can, in principle, be shared with the tax authority of any country with which the UAE has a relevant information exchange arrangement — which includes most major economies.
The significance for transfer pricing and related-party transactions deserves specific attention. Intercompany invoices between a UAE entity and a related foreign entity are within the scope of the Electronic Invoicing System as Business Transactions. Those invoices — carrying line-level detail, amounts, and dates — could be shared with the foreign tax authority through an international information exchange under Article 10(2). Businesses with complex related-party pricing arrangements should consider the Article 10(2) international sharing power as part of their transfer pricing risk assessment, not merely their UAE domestic tax compliance assessment.
Article 10 in the Context of Tax Administration 3.0
Article 10 is the statutory expression of what Tax Administration 3.0 means at the legislative level: continuous, real-time fiscal data flow from the business to the regulator, with automated data sharing across government functions and across borders. The UAE is not alone in building this architecture — Brazil's SPED system, Italy's SdI, and the emerging EU VAT in the Digital Age directive all reflect the same direction. What distinguishes the UAE implementation is the speed of deployment: a system moving from pilot to full mandatory implementation across the entire business population within approximately 18 months.
For businesses building their compliance programmes, Article 10 is not merely a data governance question. It is a tax risk management question. The data in the Electronic Invoicing System is simultaneously the compliance record (used to validate VAT returns) and the audit record (accessible to the FTA without a formal audit trigger). Designing the system to produce data that accurately reflects the underlying economic reality of every transaction — not merely data that satisfies the schematron validation rules — is the lasting compliance imperative that Article 10 creates.