Implements the Tax Procedures Law: which accounting records must be kept and for how long (generally five years, seven for real estate records), form and language of documents, tax agent registration and conduct, voluntary disclosure conditions, notification and assessment procedures; repeals Cabinet Decision No. 36 of 2017 and is amended by Cabinet Decision No. 17 of 2026.
Cabinet Decision No. 74 of 2023 is the Executive Regulation of the Tax Procedures Law. It took effect on 1 August 2023, replacing Cabinet Decision No. 36 of 2017, and is in force as amended by Cabinet Decision No. 17 of 2026 (issued 23 March 2026, effective 1 April 2026), which revised the voluntary disclosure and refund articles. It is the text that tells a business what records to keep and for how long, how to notify changes and legal representatives, when a voluntary disclosure is due, how tax agents are licensed, and how FTA audits, deadline extensions and refunds work in practice.
Article 2 defines accounting records and commercial books as the balance sheet and profit and loss accounts, wage records, fixed asset records, inventory statements and stock counts, plus the supporting correspondence, invoices, licences and contracts and any document recording a tax election or calculation. Article 3 sets the retention periods: five years after the tax period for a taxable person, five years from the end of the calendar year of creation for everyone else, and seven years for real estate records. The period extends by four years, or until the dispute ends, where there is a dispute, an ongoing audit or an audit notice; by one year after a fifth-year voluntary disclosure; and by two years while a refund application is undecided. A legal representative keeps the records for one year after its mandate ends. Article 4 allows records to be kept as originals or as identical photocopies or electronic copies that can be reproduced on request.
Article 6 lists the registration data changes that must be notified within 20 business days: name, address and email, licence activities, legal form and constitutional documents, nature of business and business address. Article 7 obliges licensing authorities to report every licence issued or renewed within 20 business days with the licensee's owners, partners and directors. Article 10, as amended from 1 April 2026, requires a voluntary disclosure within 20 business days of discovering an error that understated tax or overstated a refund by more than AED 10,000; errors of AED 10,000 or less are corrected in the next return where one is due, otherwise by disclosure within the same 20 business days.
Articles 12 to 14 set the tax agent conditions, including good conduct, three years' recent experience with a relevant degree, and duties of confidentiality and continuing professional development. Articles 15 to 19 govern audits: the FTA's decision to audit cannot be challenged, notice must be given at least 10 business days before, and the FTA may inspect premises, electronic records and accounting systems. Article 26 requires a refund decision within 20 business days and repayment procedures within five business days of approval, with refunds deferred while any return is outstanding.
Every person carrying on business in the UAE or with an obligation under a tax law, whether or not registered, their legal representatives and tax agents, the government licensing authorities that must report licences to the FTA, and the FTA itself in conducting audits, assessments, reviews and refunds.
| Article 2 | Accounting records and commercial books comprise the balance sheet and profit and loss accounts, wage and salary records, fixed asset records, inventory statements and stock counts, and all supporting documents including correspondence, invoices, licences, contracts and records of any tax election or calculation. |
| Article 3 | Records are kept five years after the tax period for taxable persons, five years from the end of the calendar year of creation for other persons, and seven years for real estate records; the period extends by four years in a dispute, audit or after an audit notice, one year after a fifth-year voluntary disclosure and two years while a refund claim is undecided. |
| Article 4 | Records may be kept as originals, or as photocopies or electronic copies identical to the originals that can be reproduced in readable form within the period the FTA sets and that allow the FTA to verify the person's tax obligations. |
| Article 6 | Registration, deregistration and reactivation follow the FTA's forms; a registrant must notify within 20 business days any change to its name, address, email, trade licence activities, legal form or constitutional documents, nature of business or business address; deregistration is completed by suspending the TRN. |
| Article 7 | Government licensing bodies must notify the FTA within 20 business days of issuing or renewing a licence, giving the licensee's name, licence details, address, activities and the details of owners, partners and directors. |
| Article 8 | A legal representative notifies the FTA of its appointment with proof, giving its own details, the taxable person's details, the duration and the responsibilities; the FTA confirms acceptance within 20 business days. |
| Article 10 | As amended from 1 April 2026, an error that understated payable tax or overstated a refund by more than AED 10,000 requires a voluntary disclosure within 20 business days of discovery; an error of AED 10,000 or less is corrected in the next return not yet due, or by disclosure within 20 business days where no return is available. |
| Articles 12–14 | A tax agent must be of good conduct, never convicted of an offence of honour or honesty, hold a relevant degree with three years' experience in the last five years, keep client information confidential, meet continuing professional development requirements and refuse any plan that would breach the law. |
| Articles 15–17 | The FTA's decision to audit is at its sole discretion and cannot be challenged; notice is given at least 10 business days before the audit with the consequences of obstruction; the FTA may inspect premises, documents, assets, electronic data and accounting systems. |
| Article 25 | The FTA may extend its own deadline for deciding a review or reconsideration request by 20 business days and the Committee may extend its objection deadline by 60 business days; both may accept late submissions for justified reasons, the Committee only for causes beyond the person's control. |
| Article 26 | The FTA decides a credit balance refund within 20 business days of the application and starts repayment within five business days of notifying approval, but may defer the refund until all outstanding returns are filed. |
| Articles 30–31 | Repeals Cabinet Decision No. 36 of 2017 while keeping FTA decisions under it in force until replaced; effective 1 August 2023, with the tax agent juridical-person provisions from 1 December 2023. |
The regulation sets no penalty amounts. Breaches of the record-keeping, notification, voluntary disclosure and audit cooperation duties it details are penalised under the Tax Procedures Law and the penalty tables in Cabinet Decision No. 40 of 2017 and Cabinet Decision No. 75 of 2023, including AED 10,000 for missing records, AED 1,000 for unreported changes, AED 20,000 for obstructing an auditor and the 1% per month and 15% penalties on undisclosed tax differences.
Our record-keeping advice to clients comes straight from Articles 2 to 4: we tell every company we administer to keep the full set of books, invoices, contracts and tax workings for five years after each tax period, seven years for anything touching real estate, and we store the corporate records we hold as registered agent on the same timetable. Article 6 is the reason our corporate secretarial team files an EmaraTax amendment whenever a client changes its licence activities, legal form, address or manager, because the 20-business-day clock starts from the change, not from the next return. The 2026 rewrite of Article 10 gives us a clear rule for client errors: anything over AED 10,000 is a voluntary disclosure within 20 business days, anything smaller goes into the next return. When an FTA audit notice arrives we use the 10-business-day lead time to assemble the Article 2 records, and we calendar the Article 3 extension that the audit itself triggers.
Tax Procedures Law
The common procedural code for all federal taxes: registration, record keeping, returns, voluntary disclosures, FTA audits and assessments, tax agents, administrative pen…
Tax Penalties Decision (VAT, Excise, Procedures)
Sets in three tables the fixed and percentage-based administrative penalties the FTA imposes for breaches of the Tax Procedures Law, the Excise Tax Law and the VAT Law, s…
Corporate Tax Penalties Decision
Lists the administrative penalties for corporate tax violations: AED 10,000 for failing to keep records (AED 20,000 on repeat), AED 500 per month rising to AED 1,000 for …
Corporate Tax Law
Imposes federal corporate tax on the taxable income of UAE companies and businesses at 0% up to a Cabinet-set threshold and 9% above it, with 0% on the qualifying income …
VAT Law
Imposes value added tax at a standard rate of 5% on supplies of goods and services and imports in the UAE from 1 January 2018, with zero-rated and exempt categories, regi…
VAT Executive Regulation
The detailed VAT rules: the AED 375,000 mandatory and AED 187,500 voluntary registration thresholds, tax groups, place and date of supply, zero-rating and exemption condi…
Whether you are establishing a new venture, restructuring an existing enterprise, or exploring residency pathways — we are here to advise.
Arrange a Consultation →