FTA Reconsideration Requests in the UAE

Article 29(1) of the Tax Procedures Law lets a person ask the Authority to reconsider "any decision, or part thereof, issued by the Authority in connection to the Person", provided the request specifies its reasons. That is the whole of the entitlement, and two words in it do most of the work: decision and reasons.

The Authority's own service card, last updated 19 August 2026, draws the boundary explicitly. Only official decisions issued by the FTA concerning the taxpayer can be reconsidered. Responses to general enquiries, responses to complaints, and clarifications are not decisions and cannot be taken through this route. That last exclusion catches people out: a private clarification is a paid product with its own service card and its own fee, and buying one does not create a reviewable decision.

What typically is a decision: a tax assessment, an estimated assessment, an administrative penalties assessment, a refusal of a registration or deregistration application, a refusal of a refund, and a decision on an application you made. If the Authority notified you of it as a decision, the 40 business days start running on that notification.

"Reasons" is not decoration either. A request that asserts the outcome is unfair without identifying the factual or legal ground it fails on gives the reviewer nothing to act on, and the service card asks for documentary proof of the grounds and any relevant tax advice received.

The window is 40 business days from the date you were notified of the decision. Business days exclude weekends and official federal government holidays under Article 1 of the Tax Procedures Law, and Article 49(1) excludes the day of the event itself from the count, so the clock starts the following business day.

Forty is the current number and it has moved. The reconsideration route sat previously under Federal Law No. 7 of 2017, repealed by Article 55 of Federal Decree-Law No. 28 of 2022 with effect from 1 March 2023; the 40-business-day figure and the whole staged ladder below it are those of the 2022 Decree-Law. That Decree-Law has since been amended twice, by Federal Decree-Law No. 17 of 2024 and Federal Decree-Law No. 17 of 2025. In the consolidation published by the Ministry of Finance on 3 December 2025, every amended article carries a footnote naming the amending decree — and Articles 28 to 37, the entire dispute ladder, carry none. Checked 21 August 2026. The ladder therefore stands as enacted in 2022.

The deadline is not absolutely rigid. Term 3 of the service card states that a person may also submit a request to extend the deadline for submitting a reconsideration request, in accordance with Federal Tax Authority Decision No. 1 of 2025. Separately, Article 35 of the Decree-Law lets the Authority or the Committee extend the periods for deciding, and lets them extend a person's own filing periods on request, for reasons set out in the Executive Regulation. An extension is a discretion to be asked for, not a right, and asking for it after the 40 days have run is a much weaker position than asking inside them.

Article 29(2) requires the Authority to review the request and issue a reasoned decision within 40 business days of receiving the application, and to inform the applicant within 5 business days of issuing it.

The service card states something that looks different: "The Authority may take up to 45 business days to respond to you from the date it receives the completed request for reconsideration." Both are correct, and they reconcile arithmetically — 40 business days to decide plus 5 business days to notify is 45 business days before the answer is in your hands. The card is describing the same statutory period from the applicant's side.

Two qualifications sit on top. The card adds that the Authority may extend the period for responding, which Article 35(1) permits for reasons specified in the Executive Regulation. And Article 31(2) gives the Tax Disputes Resolution Committee jurisdiction to decide reconsideration requests where the Authority has not made a decision on them — so silence past the deadline is not a dead end; it is itself the trigger for the next rung.

One word in Article 29(2) is worth holding onto: the decision must include reasons. A reasoned refusal is the raw material for the objection that follows it.

There are two distinct first-instance routes and they are constantly collapsed into one.

Article 28 is a tax assessment review request. It applies only to a tax assessment and its related administrative penalties, must be filed within 40 business days of notification, and the Authority has 40 business days to decide with 5 to notify. If it goes against you, Article 28(4) gives a further 40 business days to file a reconsideration against that decision — measured either from notification of it or from the expiry of the period in which the Authority should have issued and notified it.

Article 29 is the reconsideration request and reaches any decision the Authority issues about you, assessments included.

They cannot run in parallel, and the bar operates both ways. Article 28(5) prevents a review request being submitted, or continued, where a reconsideration has already been filed. Article 29(3) prevents a reconsideration of a tax assessment while a review request is pending, until the Authority decides it or the period for deciding expires. The service card repeats the second rule in its own FAQ.

The practical reading: against a tax assessment you get one extra bite by choosing Article 28 first, because a bad review decision still leaves the full reconsideration window open. Choosing reconsideration first closes the review door permanently.

The service card is unusually direct on this. A reconsideration request must be submitted to the Authority by the concerned person directly, but the Authority also accepts requests submitted by an appointed Tax Agent or an appointed Legal Representative. Where the person is a member of a tax group, the request must come from the representative member.

Then the sentence that decides a great many engagements: "Note that Tax Advisors (who are not registered as Tax Agents) are not permitted to submit any reconsideration requests on behalf of another person." The identical restriction appears on the clarifications service card. Registration on the FTA's tax agent register — not a trade licence naming tax consultancy, and not a professional qualification — is what confers the capacity to file for someone else.

Two further points from the card. You need an online profile, and sign-up is applicable to use the service. But it is not required that you be a taxable person registered with the FTA, nor that you have appointed a tax agent. A person the Authority has issued a decision against can file whether or not they hold a TRN.

Article 5(1) of the Tax Procedures Law requires every person to submit tax returns and any data, information, records and documents related to tax in Arabic. Article 5(2) then lets the Authority accept them in another language, provided the person supplies an Arabic translation if the Authority asks, as specified in the Executive Regulation. Article 5(3) puts the accuracy of any translation, and its cost, on the person submitting it, and entitles the Authority to rely on what it is given.

The reconsideration service card does not itself impose an Arabic-only requirement, and the FTA's platforms operate in English and Arabic. The honest statement of the position is therefore: an English submission is accepted in practice under Article 5(2), but the entitlement is the Authority's discretion rather than your right, and a request for an Arabic translation can arrive at any point. Where the argument turns on the wording of a document, having the Arabic ready is the cheaper posture.

Separately, failing to submit records and documents in Arabic when the Authority requests them is itself a penalised violation — AED 5,000 under both penalty schedules. That penalty is about responding to a request, not about the language you first filed in.

A reconsideration decision is not the end of the ladder, but the next rung has an entry fee.

Under Article 32(1) an objection against the Authority's reconsideration decision goes to the Tax Disputes Resolution Committee within 40 business days of being notified of it. The Committee is constituted under Article 30 as a permanent committee chaired by a member of the judicial authority with two expert members drawn from the register of tax experts. The FTA's own service card confirms where it sits: the TDRC is at the Department of Justice, not inside EmaraTax.

Article 32(2) sets out three grounds on which an objection is simply not accepted, and two of them are traps. It is not accepted if a reconsideration request was not previously submitted to the Authority — the reconsideration is compulsory, not optional. It is not accepted if the tax in connection with the objection has not been paid in full. And it is not accepted if it is filed out of time.

Article 33 gives the Committee 20 business days to decide from receipt and 5 business days to notify. Its decision is final where the total of due tax and administrative penalties does not exceed AED 100,000, and Article 34(1) makes such final decisions executory instruments. Above that threshold, Article 36 allows an appeal to the competent court within 40 business days — but Article 36(2) makes the appeal inadmissible unless the full tax is proved settled and at least 50% of the administrative penalties determined has been settled in cash or secured by an approved bank guarantee in the Authority's favour. Article 33(4) closes the circle: no tax dispute is admissible before the court unless an objection was first submitted to the Committee.

A success rate. The Authority publishes no statistics on how many reconsideration requests are granted, reduced or refused, and no figure appearing on an advisory firm's page can be traced to a source. Any percentage you are offered is invented.

The grounds on which Federal Tax Authority Decision No. 1 of 2025 will extend a deadline. The service card names the Decision as the basis for an extension request; the criteria have not been read here in the primary text and are not summarised on this page.

What a reconsideration will cost you in professional fees, or what it is worth attempting. That depends on the decision, and this firm publishes no fee schedule.

Whether a reconsideration suspends collection. Nothing in Articles 29 to 32 says that filing one stops the tax or the penalties falling due, and the Article 32(2)(b) requirement to have paid the tax in full before objecting points the other way. If cash flow is the problem rather than the merits, the instalment and waiver route under Article 50 is the separate answer.

Everything above was read on 21 August 2026 in the consolidated Tax Procedures Law and on the FTA's Reconsideration Request service card, both linked below.