How to File Reconsideration Requests in UAE Tax Assessments

A reconsideration request asks the UAE Federal Tax Authority (FTA) to review a formal decision you received, such as a tax assessment, an administrative penalty, a refund decision, or a registration decision.

In this guide, we will explain who can apply, deadlines, language requirements, grounds to raise, documents to prepare, how to file through the FTA e‑Services portal, and what happens afterward. We will also cover common errors and escalation to the Tax Disputes Resolution Committee (TDRC).

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Quick Facts and Prerequisites

• What it covers: Formal FTA decisions on Corporate Tax, VAT, or Excise (assessments, penalties, refunds, registration/deregistration, voluntary disclosure outcomes).
• Who can apply: Taxable person, recorded legal representative with valid authority, registered tax agent appointed in the FTA system, or a Tax Group’s Representative Member.
• Deadline to file: Within 40 business days from the date you were notified of the decision.
• FTA review time: Decision typically issued within 40 business days from submission; notification usually within 5 business days after the decision is made.
• Language: Submit the request in Arabic. English documents are often accepted as supporting material; provide certified Arabic translations if requested.
• Standing: Only the affected party (or its appointed representative/agent) can request reconsideration. Informal communications (emails, calls) are not decisions and cannot be reconsidered.

Tip: Rely on the exact dates and references in your notice. Weekends and UAE public holidays are not counted as business days.

Eligibility, Standing, and Grounds

Who Can Submit

• Taxable person: The entity or individual named on the decision.
• Legal representative: Holder of a valid power of attorney or court appointment recorded with the FTA.
• Registered tax agent: FTA‑accredited, appointed through the taxpayer’s account.
• Tax Group: The Representative Member files on behalf of the group; other members cannot file individually for group decisions.

What You Can Challenge

• Assessments: Disputed amounts, methods, periods, or legal basis.
• Administrative penalties: Late filing/payment penalties, or other non‑compliance penalties.
• Refund decisions: Rejections or partial approvals.
• Registration/deregistration decisions: Refusals, effective dates, or imposed conditions.
• Voluntary disclosure outcomes: Adjustments and related penalties.

Grounds to Raise

• Error of fact: Wrong figures, misclassification, wrong tax period, missing data in the initial review.
• Error of law: Incorrect application of Decree‑Laws, Cabinet/Ministerial Decisions, or official guidance.
• Procedural issue: For example, a material process defect that affected the outcome.
• New evidence: Material documents not reasonably available during the original review.

Late filing can result in rejection regardless of strength of arguments, so timing is critical.

Documents and Case‑File Preparation

Aim for a clear, indexed pack that links facts, law, and the relief requested.

• Identity and authority
  • TRN and entity details: Legal name, TRN, license number, registered address.
  • Authority to act: Power of attorney or court document for legal representatives; ensure tax agent appointment appears in the FTA account.
• Decision under review
  • Decision notice: Exact FTA letter with reference number, date, and affected periods.
  • Schedules: Any annexures and calculations attached to the decision.
• Technical case file
  • Cover letter (Arabic): Facts, issues, legal references, and the precise remedy sought.
  • Supporting evidence: Contracts, invoices, ledgers, bank proofs, customs documents, reconciliations, working papers, prior filings, correspondence.
  • Legal references: Cite relevant Decree‑Laws and Decisions where they directly apply.
  • Reconciliations: Map returns to the trial balance and bank statements; provide worksheets that a reviewer can trace.
• Format and labeling
  • Files: PDFs for letters and scanned documents; spreadsheets for reconciliations if allowed.
  • Translations: Certified Arabic translation where requested.
  • Indexing: Paginate and bookmark long PDFs; use consistent file names (for example, “Annex C – Sales ledger Q2 2024.pdf”).
  • File size limits: Split large files and label clearly.
• Relief requested
  • Be specific: Cancel penalty under Article __, reduce assessment to AED __, accept refund of AED __, amend registration effective date to __.
  • Fallback position: If helpful, provide an alternative calculation and show impact.

Step‑by‑Step Filing in the FTA e‑Services Portal

Registered Taxpayers

1. Log in: Access the FTA e‑Services portal using the taxpayer’s account.
2. Open Reconsideration: Go to the Reconsideration service in the menu.
3. Form selection: Choose the Registered Reconsideration option.
4. Enter decision details: Reference number, decision date, tax type, period(s), and remedy sought.
5. Grounds summary: Provide a concise Arabic summary; attach the full Arabic letter as PDF.
6. Upload evidence: Authority documents, FTA decision, reconciliations, and exhibits per the index.
7. Declaration and submit: Confirm accuracy; submit and save the case reference.

Non‑Registered Users

1. Create account: Register for an FTA e‑Services account and complete verification.
2. Add taxable person: Provide entity details (name, TRN or identifier, address) if prompted.
3. Open Reconsideration: Navigate to the Reconsideration page.
4. Form selection: Choose the Non‑Registered Reconsideration option.
5. Complete and submit: Fill all fields, attach the Arabic cover letter and evidence, submit, and save the case reference.

After Submission

• Acknowledgment: Keep a copy of the confirmation and case number.
• Clarifications: Monitor portal and email; respond within the stated time window and label replies with the case reference.
• Status checks: Track progress in the portal until a decision is issued.

Timelines, Outcomes, and Next Options

• FTA timeline: Decision generally issued within 40 business days of receiving the request, followed by notification within 5 business days.
• Possible outcomes:
  • Accepted: Decision amended or canceled as requested.
  • Partially accepted: Some points adjusted; others upheld.
  • Rejected: Original decision stands.
• What to do after a decision:
  • If accepted/partial: File amended returns if required, settle revised amounts, or claim refunds as instructed.
  • If rejected or only partially accepted: Consider objection to the TDRC within 40 business days from receiving the reconsideration decision, subject to eligibility and payment/guarantee conditions.

Escalation to TDRC

• Eligibility and payment condition: Objection typically requires paying undisputed tax and, for the disputed portion, payment or a bank guarantee as per current procedures.
• Timing: File within 40 business days from the reconsideration decision date.
• Committee timeline: TDRC aims to issue a verdict within 20 business days, extendable by 20 business days.
• Preparation: Address the FTA’s reasoning point by point; refine evidence and legal citations; maintain the same indexing standard.

Court routes may be available after TDRC depending on case type, thresholds, and outcome.

Penalties: Contest vs Relief

These are separate tracks and often confused.

• Contest the penalty (legal basis):
  • Use: Reconsideration.
  • Aim: Show the penalty was misapplied (wrong article, miscalculation, wrong period, or no breach).
  • Result: Cancel or reduce the penalty if grounds succeed.
• Request relief (administrative leniency):
  • Use: Relief/waiver or installment processes where available.
  • Aim: Seek reduction, reallocation, or payment plans under defined programs.
  • Note: This is different from arguing the law; criteria and forms differ.

You may contest a penalty and also request relief under a program, but they are processed on separate legal bases.

Frequent Mistakes and How to Avoid them

• Missing the 40‑business‑day filing window
  • Fix: Diary the deadline from the notification date and aim to submit a week earlier.
• Authority gaps
  • Fix: Ensure tax agent appointment is active in the FTA account and upload a valid power of attorney for legal representatives.
• Vague or generic arguments
  • Fix: Tie each claim to a specific figure, date, article, and exhibit label.
• Untraced numbers
  • Fix: Provide reconciliations that bridge returns, ledgers, and bank statements.
• Wrong decision reference or period
  • Fix: Copy details exactly from the FTA notice and attach the notice.
• Language and format issues
  • Fix: Use Arabic for the request letter; provide certified translations when asked; submit searchable PDFs rather than photos.
• Ignoring clarification requests
  • Fix: Monitor the portal and reply within the set window with complete, labeled responses.

Templates and Examples to File Reconsideration Requests in UAE Tax Assessments

Download Cover Letter Template PDF

Evidence Index (example)

• Annex A: Decision notice and schedules
• Annex B: Trial balance, return extracts, and period reconciliations
• Annex C: Sales/purchase ledgers and sample invoices
• Annex D: Bank statements and payment proofs
• Annex E: Contracts, customs documents, and correspondence
• Annex F: Legal references cited

FAQs About Filing Reconsideration Requests in UAE Tax Assessments

Who can submit a reconsideration request?

The taxable person, a recorded legal representative with authority, an FTA‑registered tax agent appointed in the account, or the Representative Member for a Tax Group.

What is the filing deadline?

Within 40 business days from the date of notification of the FTA decision.

How long does the FTA take to respond?

A decision is generally issued within 40 business days of submission, with notification within 5 business days after issuance.

Do I need to file in Arabic?

Yes, submit the request in Arabic. Supporting documents in English are common; provide certified Arabic translations if requested.

Can I include multiple issues?

If they arise from the same decision, yes. For unrelated decisions or different periods, submit separate requests.

What if I disagree with the outcome?

You may object to the TDRC within 40 business days, subject to payment/guarantee conditions and case eligibility.