A UAE VAT-registered business can request repayment of an eligible
excess recoverable VAT balance through VAT311 in EmaraTax. The amount
must be supported by correctly claimed input tax and reconciled returns.
From January 2026, time limits and transitional provisions make the age
and origin of each credit particularly important.

This guide covers business refund claims by UAE VAT registrants.
Tourist refunds, foreign-business refunds and homebuilder refunds follow
separate schemes.

Key facts

Question	Position
Which application?	VAT311, the VAT refund application
Where?	The relevant taxable-person profile in EmaraTax
Main VAT provision	Article 74 of the VAT Law
General time limit	Five years, subject to the applicable credit-origin rules, exceptions and transition
Current service estimate	25 business days for a complete application; longer investigation cases have a separate estimate
Immediate action in October 2026	Review old credits and eligible year-end transitional claims

VAT311 is distinct from a voluntary disclosure. The current
FTA refund service covers repayment of eligible input tax and excess
payments and identifies the documents and processing estimates.

When does a refundable
VAT balance arise?

A return may show excess recoverable VAT where eligible input tax
exceeds the VAT payable for the period. Common examples include an
exporter with qualifying zero-rated sales or a business making
substantial taxable-business capital expenditure before revenue
increases.

Paying VAT on purchases does not, by itself, establish recovery.
Review business use, supporting invoices, blocked categories,
apportionment, imports, reverse-charge entries and adjustments. A portal
credit also needs reconciliation to the accounting records.

For the wider framework, see our UAE VAT guide.

The five-year limit
and the 2026 transition

The FTA explains that the amended VAT Law limits the time for
requesting excess recoverable VAT to five years from the end of the tax
period from which the excess arose. Leaving it carried forward does not
preserve an unlimited right to repayment. FTA
Public Clarification VATP046, Article 74 discussion.

The Tax Procedures rules also distinguish the origin of a credit,
including excess payments, returns, disclosures and assessments.
Specific late-arising-credit exceptions may permit a one-year or 90-day
application window in the prescribed circumstances. Apply these rules to
the actual credit history. Tax
Procedures Law, Articles 38–39.

For existing balances, the Ministry of Finance describes a one-year
transitional application window from 1 January 2026 where the relevant
five-year period expired before that date or expires within the
following year. Businesses should identify eligible balances and work
towards submission before the end of 2026. Do not
assume that every invoice dated 2020 has the same expiry date or that
every credit must be approved by year-end to preserve a timely
application. MoF
transitional explanation.

Build
an ageing schedule before choosing the claim amount

Field	Why it matters
Relevant period and credit origin	Establishes the rule to apply
Original credit	Reconciles to the filed return or other source
Amount already used/refunded	Prevents duplication
Remaining balance	Establishes the amount still available
Ordinary deadline and any relief	Supports the filing decision
Evidence and application reference	Preserves a traceable claim

For example, a hypothetical AED 90,000 portal balance may contain
credits from several periods, some already partly used against later
liabilities. Its full amount cannot be assigned one age from the oldest
purchase invoice. Reconstruct the movements first.

How to submit VAT311
through EmaraTax

Step 1: Reconcile the
available balance

Match the VAT ledger, submitted VAT201 returns, previous refunds,
disclosures and portal transactions. Resolve differences before
applying. Separately assess any previously unclaimed input VAT;
first-time recovery and repayment of an existing credit are different
questions.

Step 2: Open the correct
refund service

Enter the appropriate taxable-person profile, open its VAT area and
initiate a new VAT311 claim. Read the service instructions before
completing the application.

Step 3: Verify
the amount and bank information

Check the pre-populated bank details and available refundable amount.
Enter the amount being requested and complete the required
period/transaction information. Do not assume that a partial application
automatically selects the oldest credits.

Step 4: Prepare the
required breakdowns

Use the current portal templates. Complete the questions and
transaction details relevant to the claim, including any required
explanations of supplies and adjustments.

Step 5: Attach the
evidence and submit

Review the declaration, submit through an appropriately authorised
account and retain the acknowledgement and reference. Saving the
application as a draft does not complete submission.

Step 6:
Monitor correspondence and reconcile the outcome

Respond to requests within the stated time, preserve each submission,
and reconcile approved amounts, offsets and the eventual receipt.

These steps follow the FTA’s
current VAT311 taxpayer manual. Interface details can change; use
the live instructions for the application being made.

Documents to prepare

The current service asks for input/output tax reports, invoices and
supporting documents. Depending on the claim, prepare:

• a return-to-ledger reconciliation and credit-ageing schedule;
• purchase and sales tax reports, material invoices and credit
  notes;
• export evidence supporting zero-rated sales;
• customs/import and reverse-charge reconciliations;
• recovery/apportionment workings and the basis for unusual
  expenses;
• correct bank information and the relevant supporting bank
  document;
• explanations of major changes or unusual refund balances.

Supplier and supply-verification requirements can affect input-tax
eligibility. Do not describe tax evasion as ordinary tax avoidance. For
employee expenses, apply the current specific conditions rather than
treating every staff-related expense as automatically blocked. FTA
Decision 17/2026 on employee expenses.

How long does a
business VAT refund take?

The FTA’s current published estimate is 25 business days
after a complete application. Where an audit investigation is
needed, it specifies 55 working days after all requested
information has been provided. Additional documents can lead to
a further response period. These service estimates are not a guarantee
that cash will arrive on a particular date. FTA
refund service and conditions.

Do not base cash-flow commitments on an unapproved refund.
Outstanding liabilities, queries or the applicable audit conditions may
affect the outcome.

What if the FTA
rejects or reduces the claim?

Reconcile the written decision to the application and identify the
disputed issue. Preserve notification evidence and assess the applicable
challenge deadline promptly. See our FTA
VAT reconsideration guide.

Retain the underlying records while the matter remains open. The
April 2026 procedural amendments introduce additional retention in
specified unresolved refund circumstances. MoF
procedural update.

Frequently asked questions

Can a business carry
a VAT credit forward?

Yes, subject to the applicable time limit and utilisation rules.
Carry-forward is not an indefinite alternative to reviewing old
credits.

Does
a purchase invoice dated 2020 determine the refund deadline?

Not by itself. Identify when and how the recoverable credit arose,
how it was reported and used, and which transitional or exception
provisions apply.

Does a VAT
refund application guarantee repayment?

No. The underlying recovery must be valid, the evidence sufficient
and the claim timely. The FTA can query or adjust the amount and apply
the relevant offset rules.

Is VAT311 the tourist
refund process?

No. VAT311 in this guide concerns registered-business claims. Other
refund schemes have separate eligibility and procedures.

How BPOAS can help

BPOAS reviews underlying accounting records and supporting documents
before a business refund claim is prepared. We can help reconcile
returns, organise the credit history and identify documentation gaps,
with submission handled through the eligible person or properly
appointed representative.

Book a VAT
refund-balance review or return to the BPOAS
compliance hub.

General guidance based on sources checked on 15 October 2026.
Confirm the precise deadline and treatment of each balance before
submission.