How to file an FTA reconsideration request in the UAE

What is an FTA reconsideration request in the UAE?

An FTA reconsideration request in the UAE is a formal written application asking the Federal Tax Authority (FTA) to review a decision it has issued, such as a tax assessment or administrative penalty. It is the first step in the UAE tax dispute process and must be filed in Arabic within 40 business days of the original decision.

This guide explains who can file an FTA reconsideration request in the UAE, the legal deadlines, what to include, and what to do if the FTA rejects your application. It sits inside our wider FTA Compliance UAE hub, which covers audits, penalties, and disclosures.

When you can file an FTA reconsideration request

You can request reconsideration of almost any FTA decision that affects you, including value added tax (VAT) assessments, corporate tax assessments, excise tax decisions, and administrative penalties. The request asks the FTA itself to look at the matter again before you move to an independent body.

The legal basis is Federal Decree-Law 28 of 2022 on Tax Procedures, as updated by Federal Decree-Law 17 of 2024. The law sets out a fixed process and strict time limits. Missing the deadline usually means the decision becomes final.

Common decisions people contest

• VAT assessments and reassessments after a tax audit.
• Corporate tax assessments under Federal Decree-Law 47 of 2022.
• Administrative penalties for late filing, late payment, or record-keeping breaches.
• Penalties linked to voluntary disclosures.
• Refund rejections and excise tax decisions.

When reconsideration is not the right route

Some matters are handled through different channels. Penalty waiver applications, instalment plans, and voluntary disclosures are separate procedures. If you spot an error in a past return before the FTA does, see our guide to Voluntary Disclosure UAE All Taxes and on Voluntary Disclosure UAE Timing.

Deadlines and the dispute timeline

The reconsideration stage is bound by tight statutory deadlines. The clock runs in business days, not calendar days, and starts on the day after you are notified of the decision.

If the FTA does not respond within its 40 business day window, the request is treated as rejected and you can move to the next stage. Always pay the disputed tax and penalties on time unless you have a confirmed instalment arrangement, since interest keeps running.

What happens if you miss the 40 day window

A late reconsideration request is normally inadmissible. The FTA decision then becomes final and enforceable. In limited cases, the FTA may accept a late filing if you can show a valid reason such as serious illness or force majeure, but this is discretionary and rare.

Who can file the request

The reconsideration request must be filed by the taxpayer or a duly authorised representative. The taxpayer can be a natural person, a UAE company, a free zone entity, or a foreign business with a UAE tax registration number (TRN).

Authorised tax agents

A registered UAE tax agent listed on the FTA register can file on your behalf. You will need a signed engagement letter and a power of attorney. For corporate taxpayers, the signatory must be a director or someone with documented authority from the board.

Group registrations

For VAT groups, the representative member files the request. For tax groups under corporate tax, the parent company files for the group. Make sure the TRN, trade licence, and signatory details match the FTA records exactly.

Grounds for a strong reconsideration request

The FTA expects clear legal and factual grounds, not just disagreement with the outcome. The strongest applications tie each argument to a specific article of the relevant law and to documentary evidence.

Legal grounds

• The FTA applied the wrong article of the VAT, excise, or corporate tax law.
• The decision contradicts a published FTA public clarification or guide.
• The penalty falls outside the schedule in Cabinet Decision 49 of 2021 or Cabinet Decision 106 of 2025.
• The statute of limitations has expired for the tax period in question.

Factual grounds

• The FTA used incorrect figures, dates, or supplier details.
• Supporting documents existed but were not considered.
• The transaction was zero rated, exempt, or out of scope under the law.
• A clerical or arithmetic error inflated the assessment.

Procedural grounds

• The decision was issued without the required notice or audit procedure.
• Translations of key evidence were not accepted in time.
• The decision was sent to the wrong address or representative.

What to include in your submission

The FTA requires a complete file in Arabic. English documents must be translated by a Ministry of Justice approved legal translator. Incomplete submissions are returned and the 40 day window keeps running, so prepare carefully.

Core documents

1. A covering letter in Arabic stating the decision reference, date, and the relief sought.
2. A copy of the FTA decision being challenged.
3. The trade licence and TRN certificate of the taxpayer.
4. Emirates ID and passport copy of the authorised signatory.
5. Power of attorney if filed by a tax agent or law firm.
6. A detailed grounds memorandum, with references to the law.
7. All supporting evidence: invoices, contracts, bank statements, customs documents, and ledgers.

Format and language rules

The grounds memorandum and covering letter must be in Arabic. Supporting evidence can be in English but should be accompanied by a certified Arabic translation for the items the FTA needs to read in detail, such as contracts and key invoices. PDF files should be clear, searchable where possible, and named in a logical order.

How to file the FTA reconsideration request

Reconsideration requests are submitted through the FTA's EmaraTax portal under the dedicated reconsideration service. The portal walks you through the decision reference, the tax type, and the supporting document upload.

Step by step

1. Log in to EmaraTax with the taxpayer account, not a personal account.
2. Open the reconsideration service and select the decision you want to contest.
3. Confirm the decision date and the 40 business day deadline displayed.
4. Upload the Arabic covering letter, grounds memorandum, and evidence.
5. Verify the contact details for FTA correspondence.
6. Submit and save the reference number for tracking.

You can review the official process on the Federal Tax Authority website and check related ministerial decisions on the UAE Ministry of Finance website.

What the FTA will do next

The FTA assigns a reviewer who examines the file independently of the team that issued the original decision. The reviewer can ask for clarifications, request additional documents, or set up a meeting. Respond to any clarification request within the time given, usually 5 to 10 business days.

Possible outcomes

• Full acceptance: the FTA cancels the assessment or penalty.
• Partial acceptance: the FTA reduces the amount or adjusts the period.
• Rejection: the FTA upholds the original decision.
• Deemed rejection: no response within 40 business days.

If your reconsideration is rejected

A rejection is not the end of the road. You have 40 business days from the FTA decision to escalate the matter to the UAE Tax Dispute Resolution Committee. To be eligible, you must have filed the original reconsideration on time and paid the undisputed tax.

If the committee rules against you, you can appeal to the federal courts. Our guide on UAE Tax Court Procedures explains the timelines, court fees, and evidence rules for that stage.

Related remedies you should know

Reconsideration is about whether the decision was correct in law and fact. Separate procedures exist to soften the financial impact:

• Apply for a Penalty Waiver UAE Grounds where there is a valid reason for non-compliance.
• Request a Penalty Instalment Request UAE to spread payment over time.
• Use a voluntary disclosure to correct errors before the FTA issues an assessment.

Worked example

A Dubai trading company receives a VAT assessment of AED 180,000 plus a 50% penalty for a 2023 tax period. The assessment treats export sales as standard rated because customs exit certificates were not on file at the audit visit. The company later locates the certificates from its freight forwarder.

Action plan

1. Calendar the 40 business day deadline on the day the assessment is received.
2. Engage a registered tax agent to draft the Arabic grounds memorandum.
3. Cite Article 45 of the VAT Decree-Law on zero rating of exports and the relevant Executive Regulation.
4. Attach customs exit certificates, commercial invoices, transport documents, and bank receipts.
5. File through EmaraTax and pay any undisputed VAT to stop interest.

If the FTA accepts the evidence, the assessment and linked penalty are cancelled. If only partial relief is granted, the company can take the remaining amount to the Tax Dispute Resolution Committee within 40 business days.

Practical tips that improve your odds

• Start drafting the Arabic memorandum on day one, not in the final week.
• Keep a single source of truth for evidence with a clear file index.
• Quote specific articles of the law, ministerial decisions, and public clarifications.
• Address every point in the original FTA decision, not just the ones you find easy.
• Be factual and professional in tone, avoid emotive language.
• Save the EmaraTax reference number and all FTA correspondence in one folder.

For a full view of your obligations and rights, return to the FTA Compliance UAE hub, which links to related procedures, penalty schedules, and audit guidance.

Talk to a UAE specialist

EInvoice Direct is built by Massive FZCO, a Dubai software studio that works with UAE finance teams every day. If you are weighing up a reconsideration, a voluntary disclosure, or wider e-invoicing readiness, see how EInvoice Direct works and request UAE pricing tailored to your business.