Parties and roles
Importer of record
The person or company legally responsible for an import: the declaration, the duties and taxes, and compliance with import rules.
In four languages
The importer of record is the party in whose name the import declaration is filed. It is liable for correct classification and value, pays the duty and VAT, and answers to customs afterwards. In the UAE, a mainland importer needs a trade licence with an import activity and a customs client code with the customs of that emirate; to use the VAT reverse charge, the code must be linked to its tax registration number. A free zone company can import into its own zone with duty suspended. Example: a Chinese supplier offers DDP Dubai, but has no UAE licence or customs code. Someone else must then act as importer of record, and the buyer may lose the right to recover import VAT. A VAT-registered buyer is often better off buying DAP and clearing in its own name.
Questions
Can a foreign company be the importer of record in the UAE?
Not directly. It needs a local licensed company to act as importer, consignee or buyer, and clearance is then filed under that company's customs code.
Is the importer of record the same as the consignee?
Usually yes in Gulf practice, but not always. The consignee receives the goods, while the importer of record is whoever files and is liable for the declaration.