How to file a VAT reconsideration request in the UAE

What is a VAT reconsideration request in the UAE?

A VAT reconsideration request in the UAE is a formal application asking the Federal Tax Authority (FTA) to review and potentially reverse or amend a decision it has made. These decisions typically involve tax assessments, penalties, or refund rejections. The process is governed by Federal Decree-Law 17 of 2024 on tax procedures and gives businesses a structured way to challenge FTA rulings before escalating to the courts.

If you operate under the UAE VAT regime, understanding this process is essential. The FTA issues thousands of penalty notices and assessment decisions each year. Many of those decisions can be corrected, reduced, or overturned through a well-prepared reconsideration request.

When can you submit a reconsideration request?

You can submit a reconsideration request whenever the FTA issues a decision you believe is incorrect or unjust. Common triggers include:

• A tax assessment you disagree with after a VAT audit in the UAE.
• An administrative penalty you consider disproportionate or wrongly applied.
• A rejected VAT refund application.
• A denied VAT registration or de-registration request.
• Any other formal FTA decision that affects your tax position.

You do not need to wait for a specific penalty type. The right applies to virtually any FTA decision communicated to you in writing.

Deadline for filing

You must submit the reconsideration request within 40 business days from the date you were notified of the FTA decision. Missing this window means losing your right to administrative review. The only remaining option after that is a direct appeal to the Tax Disputes Resolution Committee (TDRC), which has its own separate deadlines and procedures.

Mark the notification date carefully. The 40-business-day clock starts from the date shown on the FTA's notification, not the date you actually read it.

Step-by-step process for filing a reconsideration request

The entire process is handled through the FTA's online portal at tax.gov.ae. There is no paper-based option.

Step 1: Log in to the FTA portal

Use your Tax Registration Number (TRN) and credentials to access your account on the EmaraTax platform.

Step 2: Locate the decision

Navigate to the "Reconsideration" section. The portal will list FTA decisions linked to your TRN. Select the specific decision you want to challenge.

Step 3: State your grounds

Write a clear explanation of why you believe the decision is wrong. Reference specific legal provisions, transaction records, or factual errors. Vague objections like "the penalty is too high" are unlikely to succeed.

Step 4: Attach supporting documents

Upload all evidence that supports your case. This may include:

• Tax invoices and credit notes.
• Contracts or purchase orders.
• Bank statements proving payment dates.
• Correspondence with the FTA.
• Corrected VAT return calculations.
• A voluntary disclosure filed before the decision, if relevant.

Step 5: Submit and pay the fee

There is no government fee for filing a reconsideration request with the FTA. Submit the form and save your confirmation receipt.

Step 6: Wait for the FTA's response

The FTA must issue its decision on the reconsideration within 40 business days of receiving your complete request. If the FTA does not respond within that period, the request is considered rejected by default.

What happens after the FTA responds?

The FTA can accept, partially accept, or reject your reconsideration request. Here is what each outcome means for your next steps.

FTA Decision	What It Means	Your Next Step
Fully accepted	The original decision is reversed or the penalty is cancelled.	No further action needed. Any overpaid amounts are credited to your tax account.
Partially accepted	The penalty or assessment is reduced but not eliminated.	Accept the revised decision or escalate to the TDRC within 40 business days.
Rejected	The FTA upholds its original decision in full.	Escalate to the TDRC within 40 business days of the rejection notice.
No response within 40 business days	Deemed rejection by default.	Escalate to the TDRC within 40 business days of the deemed rejection date.

Escalation path: TDRC and beyond

If the reconsideration fails, you can appeal to the Tax Disputes Resolution Committee. The TDRC is an independent body that reviews FTA decisions. You must file the TDRC appeal within 40 business days of the reconsideration outcome.

For disputes involving amounts of AED 100,000 or less, the TDRC's decision is final. For amounts above AED 100,000, either party can further appeal to the competent court within 40 business days of the TDRC ruling.

Key point on payment obligations

Filing a reconsideration request does not suspend your obligation to pay the assessed tax or penalty. You must still pay the amount by the original due date. If the FTA later accepts your reconsideration, the overpaid amount is refunded or credited. Failing to pay while disputing can trigger additional late VAT payment penalties.

Common reasons reconsideration requests succeed

Based on the types of decisions the FTA commonly reverses, these factors tend to strengthen a request:

• Factual errors by the FTA. The FTA miscalculated your taxable supplies or applied the wrong tax period.
• Duplicate penalties. You were penalized twice for the same violation.
• Reasonable excuse. You can demonstrate circumstances beyond your control, such as system outages or medical emergencies, that caused the non-compliance.
• Voluntary correction. You filed a voluntary disclosure and corrected the error before the FTA discovered it, which may reduce or eliminate penalties.
• Procedural errors. The FTA did not follow proper notification procedures.

Common reasons reconsideration requests fail

Equally important is knowing what does not work:

• No supporting evidence. Claims without documents are almost always rejected.
• Late filing. Submitting after the 40-business-day window.
• Disagreeing with the law itself. The FTA cannot waive a penalty that the law mandates. Your argument must be that the law was misapplied, not that the law is unfair.
• Repeat offences. If you have a history of the same violation, the FTA is less likely to grant relief.

Reconsideration request checklist

Use this checklist before submitting your request to avoid common mistakes.

1. Confirm the FTA decision date and verify you are within 40 business days.
2. Identify the specific legal ground for your objection (cite the relevant article of the tax law or executive regulation).
3. Gather all supporting documents: invoices, returns, bank records, contracts.
4. Write a clear, factual summary. Avoid emotional language.
5. Pay the disputed amount by the original due date to avoid additional penalties.
6. Save a copy of your submission confirmation from the FTA portal.
7. Set a calendar reminder for 40 business days after submission to track the FTA's response deadline.

How reconsideration connects to the broader penalty framework

The reconsideration process exists within the UAE's wider VAT compliance structure. UAE VAT penalties range from AED 2,500 to AED 50,000 per violation under Cabinet Decision 106 of 2025. Understanding the penalty schedule helps you assess whether a reconsideration is worth pursuing or whether the cost of preparation outweighs the potential savings.

For serious cases involving intentional misreporting, the FTA may also pursue VAT tax evasion penalties, which carry much heavier consequences. A reconsideration request is not the right tool for evasion allegations. Those cases typically require legal representation from the outset.

Staying compliant with UAE VAT obligations, including timely filing, accurate record-keeping, and correct invoice formatting, is the best way to avoid needing a reconsideration request in the first place.

If you want to reduce compliance errors and keep your VAT invoicing accurate from the start, see how EInvoice Direct works and get UAE e-invoicing pricing today.