Two TRNs, one invoice: VAT or corporate tax number?

Corporate tax registration gave VAT-registered businesses a second Tax Registration Number. According to the FTA's corporate tax registration guide, it looks like the existing VAT or excise TRN, "but the last digit will be different". Two 15-digit numbers separated only by their final digits are easily confused, and many invoice templates now show the wrong one.

The right number for a tax invoice

It is the VAT TRN. Article 59 of the VAT Executive Regulation requires the supplier's Tax Registration Number on every tax invoice, plus the customer's where they are registered, and in VAT law that means the VAT TRN.

Why it will matter from 2027

An incorrect TRN on a PDF can survive unnoticed for years. On an e-invoice it cannot. The PINT AE specification contains a fatal validation rule: the VAT identifier must be 15 digits, start with 1 and end with 03. The Ministry of Finance's own example TRNs end in 003. A number ending in 01 fails, and the invoice is rejected before it reaches the customer.

Telling the two apart

• Both have 15 digits, and only the end differs.
• The VAT TRN ends in 03, under the e-invoicing rule.
• A number ending in 1 is very likely the corporate tax TRN. The FTA says only the last digit differs, and a consultant quoted by Gulf News in May 2024 described the corporate tax number as the VAT number with a suffix of 1. The FTA has not officially explained the endings.
• To be sure, look at your VAT registration certificate, or use the TRN verification tool on the FTA website.

And the TIN

E-invoicing introduces a third identifier, the Tax Identification Number. It is the first 10 digits of your TRN and forms your Peppol address, 0235 followed by the TIN. The Ministry describes it in some documents as the first 10 digits of the corporate tax TRN and in others as the first 10 digits of the TRN issued to you. The two numbers share those digits, so either way the TIN is the same.

• In a tax group, your TIN comes from your own corporate tax TRN rather than the group representative's.
• A business with no tax registration at all must register with the FTA for a TIN before e-invoicing.
• A seller without a TRN uses its TIN on a commercial e-invoice instead.

A quick check

• Your invoice template: does the TRN end in 03?
• The TRN stored in your accounting or invoicing software.
• Your customers' TRNs, since a customer who supplied their corporate tax number will cause every e-invoice to them to fail.
• Your trade licence number and issuing authority, which e-invoices also include.

It takes five minutes to check and saves a year of rejected invoices later. If you would like ALXO to review your invoice templates and records, get in touch.