A reconsideration request asks the Federal Tax Authority to review an
official decision concerning the applicant. It generally must be
submitted within 40 business days of notification and
explain the legal and factual grounds. Assessment review, penalty
relief, TDRC objection and court appeal are distinct procedures with
separate conditions.
This guide is for businesses reviewing a VAT assessment, penalty or
refund decision. The general Tax Procedures framework also applies
across other federal tax types, subject to the relevant provisions.
Start with
the decision and its notification date
Obtain the full decision, assessment calculations and notification
evidence. Record when and how notification occurred. Do not assume that
the date a staff member happened to open an email determines the legal
deadline.
Check whether the communication is an official decision. General
enquiries, complaints and clarification responses are not automatically
eligible for reconsideration. The FTA
reconsideration service explains the current eligibility and
exclusions.
Reconsideration
deadlines and response time
| Item | Current position |
|---|---|
| Normal application deadline | 40 business days from notification |
| Statutory decision period | 40 business days, followed by five business days for notification |
| FTA service description | Up to 45 business days from a complete application, subject to extension |
| Extension of application deadline | May be requested under the applicable conditions; not automatic |
| Portal route | Taxable Person Profile → Other Services → Reconsiderations → New Request |
The response estimate and extension route are described in the current
FTA service card. Calculate business days carefully using applicable
holidays and retain a deadline worksheet.
Choose the correct route
Tax Assessment Review
A Tax Assessment Review is a separate mechanism under Article 28. Its
relationship with reconsideration is procedural: an assessment-review
application cannot simply continue after reconsideration has been filed,
and reconsideration of the assessment cannot run while an assessment
review is pending until the prescribed decision period has ended or a
decision is issued.
Reconsideration
Use reconsideration to challenge an official decision on identified
legal or factual grounds. State what should change and why, supported by
the relevant records.
Penalty waiver or
instalments
A request for relief from a correctly imposed penalty differs from an
argument that the decision itself is wrong. A genuine mistake, financial
difficulty or good compliance history should not be presented as an
automatic legal entitlement to cancellation. Assess the separate relief
criteria and any concurrent-application rules.
The assessment-review relationship and eligible applicants are
explained in the FTA
reconsideration service. Seek procedural advice early where more
than one route may be relevant.
How to
prepare and submit a reconsideration request
Step 1: Identify each
disputed item
List the decision reference, tax type, period, tax amount, penalty
amount and exact issue. A disagreement with a tax calculation may
require different evidence from a challenge to late filing.
Step 2: Build an evidence
index
Organise a short chronology, returns, invoices, contracts,
correspondence and calculations. Link each document to a numbered ground
rather than uploading an unexplained collection of files.
| Ground | Useful evidence |
|---|---|
| Incorrect tax calculation | Reconciliation and corrected calculation |
| Wrong supply treatment | Contract, invoice, transaction facts and relevant provision |
| Recovery rejected | Invoice, business purpose, receipt/supply evidence and recovery analysis |
| Documented portal issue | Dated screenshots, support references and submission-attempt evidence |
These are preparation examples, not predictions that a particular
ground will succeed.
Step 3: State the
legal and factual grounds
Explain what the decision concluded, the point being challenged, the
applicable provision, and how the evidence supports a different result.
Separate facts from interpretation and identify the requested correction
precisely.
Step 4: Confirm the
permitted applicant
The concerned person can apply. The FTA also accepts applications
through an appointed tax agent or legal representative under the
applicable rules. A tax adviser who is not registered as a tax agent may
not submit for another person merely because the adviser prepared the
document. Tax-group applications have representative-member
requirements. FTA
applicant rules.
Step 5: Submit through
EmaraTax
Open the correct taxable-person profile and the reconsideration
service, complete the form, attach the indexed evidence and submit
before the deadline. Check the current file and language requirements.
Keep the final application, acknowledgement and notification record.
Step 6: Monitor the case
Respond to information requests, keep a complete correspondence file
and diarise the next procedural step. A draft application is not a
submitted request. An extension request should not be treated as granted
until its status is confirmed.
What follows if
the dispute remains unresolved?
The ordinary taxpayer route is governed by Federal Decree-Law
28 of 2022, as amended:
| Stage | Core statutory condition |
|---|---|
| TDRC objection | Generally within 40 business days of notification of the reconsideration decision; prior reconsideration and full tax payment required |
| Committee finality | Decisions where total tax and penalties do not exceed AED 100,000 are final under the statutory rule |
| Court appeal where available | Generally 40 business days; full tax payment and at least 50% of administrative penalties paid or secured as prescribed |
These are different admission rules. There is no general “100% bank
guarantee, waived below AED 50,000” rule for TDRC objections. Special
procedures can apply to government entities. Tax
Procedures Law, Articles 29–37.
The FTA also describes a committee route when it has not decided
reconsideration within the prescribed time. Obtain advice on the
deadline and competent forum for that circumstance. TDRC submissions and
supporting documentation require Arabic under the FTA
committee guidance.
Payment
and dispute rights must be managed separately
Do not delay payment simply because a challenge is being prepared, or
describe payment as acceptance of the assessment. Review payment,
collection and challenge requirements together. Do not assume that
submitting reconsideration automatically suspends enforcement or
penalties.
For court proceedings, verify jurisdiction, admissibility and
representation requirements with qualified legal counsel. The correct
court should not be assumed from the business’s trade-licence address
alone.
VAT issues that
need current legal analysis
An input-tax dispute may involve invoice validity, business use,
apportionment, supplier verification or evasion-linked transactions. The
evasion provision is VAT Law Article 54 bis; it should not be attributed
to a general penalty-relief discretion. FTA
VATP046.
Likewise, do not assume every error can be fixed through an amended
return. Determine whether the relevant correction or
voluntary-disclosure rules apply before an assessment or challenge is
prepared.
Frequently asked questions
What is the FTA
reconsideration deadline?
Generally 40 business days from notification of the official
decision. Preserve notification evidence and assess any permitted
extension promptly.
Can a business go
directly to the TDRC?
Prior reconsideration is a statutory gateway for the ordinary
objection route. Failure by the FTA to decide within the prescribed
period requires a separate procedural assessment.
Can BPOAS prepare
the evidence and grounds?
BPOAS can support accounting reconciliations, the evidence file and
preparation of the request. Submission must be by the eligible person or
appropriately appointed representative.
Does
reconsideration guarantee a penalty reduction?
No. It addresses the decision under the relevant law and evidence. A
separate waiver or instalment request has its own criteria.
How BPOAS can help
BPOAS helps clients understand the accounting basis of an assessment,
reconstruct the supporting record and prepare a clear technical file.
Where legal representation or registered-tax-agent submission is needed,
the appropriate arrangements should be confirmed.
Request a review of
your FTA decision. Related reading: UAE VAT
refunds, UAE VAT
and the BPOAS
compliance hub.
General guidance based on sources checked on 15 October 2026.
Dispute deadlines, notification and admissibility are case-specific;
obtain advice promptly after receiving a decision.
