The date of supply prescribes the point in time when a VAT Registrant needs to account for VAT. The date of supply is determined either as per the general rules or the special rules, depending on whether there will be periodic payments or consecutive invoices.

This Public Clarification vide circular No.: VATP009 discusses the date of supply for the Board fees paid to Independent Directors

Where the Board fees for the Independent Directors are not known and are determined upon conclusion of Annual General Meeting, the date of supply would be when fees are known. In other cases where the Board fees are known at the outset, the date of supply would be determined as per Article 26 VAT Law i.e. in case of periodic payments or consecutive invoices. However, where there are no periodic payments or consecutive invoices, the date of supply would be determined as per Article 25 of the VAT Law.

Date of Supply, if the Board fees are known and periodic payments, the date of supply would be earliest of:

• Date of issuance of tax invoice;
• The date payment is due as shown on the tax invoice;
• Date of receipt of payment.

However, if 12 months have passed from the date of provision of services and none of the aforesaid events has occurred, the date of supply will be determined at the end of the 12th month.

Date of Supply, if the Board fees are known but no periodic payments, the date of supply would be earliest of:

• Date of issuance of a tax invoice;
• The date on which the provision of services was completed;
• Date of receipt of payment.