FTA Decision 5/2021 — FTA policy on clarifications and directives (2026 version)

Factual summary

Sets the FTA's policy for issuing clarifications and directives. It covers private clarifications requested by a taxpayer, public clarifications and guides, and four kinds of directives: administrative exceptions, alternative input-tax apportionment methods, unilateral advance pricing agreements and directives on tax transactions. Directives on tax transactions are published decisions that bind both the FTA and taxpayers.

What it means in practice Professional insight

Who: taxpayers that need certainty on a specific position. What to know: which route applies (private clarification, administrative exception, apportionment method, advance pricing agreement), the minimum information a request must contain, and that published directives on tax transactions are binding.

Key provisions

• Art. 1–2 The FTA issues clarifications and directives under the attached policy; the current version came into effect on 1 March 2026.
• Section III Clarifications: private clarifications issued on a taxpayer's request through the FTA form, public clarifications, guides and e-learning.
• Section IV.1–3 Directives: administrative exceptions (tax invoices, credit notes, export evidence and periods), alternative input-tax apportionment methods, and unilateral advance pricing agreements (currently for domestic related-party transactions only).
• Section IV.4 Directives on tax transactions are published decisions that bind both the FTA and taxpayers; they lapse when the legislation they rest on is amended or when replaced.