Arslan Malik Published in
Lexis Middle East

Lexis Middle East, a LexisNexis legal and regulatory journal covering the Middle East and North Africa, published an analysis by Rise Accounting’s Arslan Malik examining the VAT framework — and the significant gaps within it — facing businesses entering the UAE’s newly established commercial gaming sector.

Published by: Lexis Middle East (LexisNexis)

Publication date: April 2026

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Background

The UAE legalised commercial gaming in September 2023 becoming the first Arab Gulf state to do so. Within two years, licensed online platforms were live and a major casino development was underway in Ras Al Khaimah. It is a sector that has moved from concept to operational reality at speed.

What hasn’t moved as quickly is the tax framework. The UAE’s VAT legislation was written when gaming was entirely prohibited. There is currently no guidance from the Federal Tax Authority on how gaming revenue should be treated, no gaming-specific VAT rules, and genuine ambiguity around the correct taxable base — the figure from which VAT liability is calculated.

Arslan’s article, published in Lexis Middle East in April 2026, examines that gap in detail. It sets out the current VAT position, identifies the specific questions operators need to resolve before entering the market, and draws on EU VAT case law to map the most likely path forward.

For any business operating in the UAE’s gaming sector, or evaluating it as a new market, this analysis matters. Getting the tax position wrong from the outset isn’t a minor compliance issue. At transaction volumes typical of gaming operations, the commercial exposure is significant.

About Lexis Middle East

Lexis Middle East is part of the LexisNexis group, one of the world’s leading providers of legal, regulatory, and business intelligence. The platform serves legal professionals, in-house counsel, and financial advisers operating across the Middle East and North Africa region.

Publication in its e-journal is editorially selective. Contributors are chosen on the basis of subject matter expertise and the practical value of their analysis, not commercial relationships. For Rise Accounting’s work to be featured alongside established regional legal and tax practitioners reflects the depth of specialist knowledge the firm brings to cross-border and UAE-specific matters.

What the article covers

The regulatory background

How the GCGRA was established, what the five licence categories cover, and how quickly the sector moved from legal framework to operational reality.

The current VAT policy vacuum

Why the default 5% position under UAE VAT Decree-Law No. 8 of 2017 creates a fundamental taxable base problem and what that means for operators calculating their liability.

Specific VAT questions operators face right now

Free bets and complimentary plays. Refunds, bad debts, and fraud losses. Loyalty points and non-cash prizes. Shared jackpot pools across multiple operators. Online gaming as electronically supplied services (ESS) and what that means for offshore operators serving UAE-resident players.

The case for VAT exemption

Drawing on CJEU case law, Arslan sets out why full VAT exemption, mirroring the EU approach, is the most practical resolution available to the FTA, and analyses the commercial trade-offs operators face under an exempt treatment.

Why this publication matters

A sector moving faster than its tax framework

The UAE’s commercial gaming sector went from entirely prohibited to operationally live in under two years. The first licensed platforms launched in December 2025. A regulated casino development is underway in Ras Al Khaimah. The VAT position has not kept pace and for businesses entering this market, that gap creates real financial exposure.

Published in a primary legal reference source

Lexis Middle East is part of the LexisNexis group and serves as a primary reference for legal professionals, in-house counsel, and financial advisers across the MENA region. Editorial selection is based on expertise and analytical rigour, not commercial relationships.

Forward analysis for decisions that can’t wait

Official FTA guidance on gaming VAT does not yet exist. Arslan’s article draws on EU VAT case law — the most developed analogical framework available — to map the most likely path forward. For businesses that need to make investment and structuring decisions now, that kind of analysis has direct commercial value.

What this means for businesses

Businesses that are already operating in the UAE and considering gaming, lottery, or sports wagering as part of business activity, or for businesses that supply technology, marketing, or ancillary services to operators in this space, the VAT position needs to be part of planning now, not once official guidance arrives.

For businesses outside the UAE or evaluating it as a new market, the opportunity is real. The regulatory framework is in place, licences are being issued, and the first platforms are live. But this is a heavily regulated sector with serious compliance requirements across licensing, anti-money laundering, and player protection, on top of an unsettled tax position that requires specialist input before businesses commit.