Federal Decree-Law No. 28 of 2022 · UAE Federal
The common procedural code for all federal taxes: registration, record keeping, returns, voluntary disclosures, FTA audits and assessments, tax agents, administrative penalties and reconsideration, objections to the Tax Disputes Resolution Committee and courts, refunds and evasion offences; repeals Federal Law No. 7 of 2017 and is amended by Federal Decree-Laws No. 17 of 2024 and No. 17 of 2025.
Federal Decree-Law No. 28 of 2022 is the Tax Procedures Law, the common procedural code for corporate tax, VAT and excise tax. It took effect on 1 March 2023, repealing Federal Law No. 7 of 2017, and is in force as amended by Federal Decree-Law No. 17 of 2024 (effective 30 October 2024, which added the Electronic Invoicing System to Article 4 bis) and Federal Decree-Law No. 17 of 2025 (effective 1 January 2026, which rewrote the statute of limitation in Article 46 and made it the single limitation rule for all federal taxes). Article 3 applies it to the administration and enforcement of the tax laws and the collection of tax and penalties; each tax law then applies it wherever the tax law is silent.
Articles 4 to 7 set the standing obligations: keep accounting records and commercial books under the Executive Regulation's controls, submit returns and documents in Arabic or provide an Arabic translation on request at the person's own cost, quote the tax registration number, notify the FTA within 20 business days of any change to registration data, and, for a legal representative, notify the appointment within 20 business days and file the returns. Article 10 makes a voluntary disclosure compulsory where a return, assessment or refund application understated the tax or overstated the refund, and optional where the error went the other way; errors with no tax difference are corrected by disclosure or in a return.
Articles 12 to 15 regulate tax agents and Articles 16 to 22 govern FTA audits. Article 24 requires an administrative penalty assessment, notified within five business days, for the standard list of breaches: records, Arabic documents, late registration and deregistration, unreported changes, late returns, late payment, incorrect returns, voluntary disclosures and audit obstruction. Article 25 makes tax evasion a crime punishable by imprisonment and a fine of one to three times the evaded tax, with up to AED 1,000,000 for false information, concealing or destroying records or obstructing FTA staff; participants are jointly liable for the tax.
Articles 28 to 36 set the dispute ladder, each step within 40 business days: a review request of an assessment, a reconsideration request of any FTA decision, an objection to the Tax Disputes Resolution Committee (admissible only after reconsideration and payment of the disputed tax in full), and an appeal to the competent court, which requires payment of the tax and at least 50% of the penalties. Committee decisions on disputes up to AED 100,000 are final. Article 38 limits refund applications to five years. Article 46 bars audits and assessments more than five years after the end of the tax period, extended to four years after an audit notice, one year after a late voluntary disclosure or two years after a late refund claim, and to 15 years for tax evasion or failure to register.
Every person subject to corporate tax, VAT or excise tax in the UAE, including those who should be registered but are not, their legal representatives and tax agents, government licensing bodies that must notify the FTA of licences issued, and the Federal Tax Authority, the Tax Disputes Resolution Committee and the courts that administer tax disputes.
English official text in 51 articles. Open the full text or jump to a provision:
| Article 4 and 4 (bis) | Any person conducting business or with a tax obligation must keep accounting records and commercial books under the Executive Regulation's controls; the Minister determines who is subject to the Electronic Invoicing System and its effective dates (added by Federal Decree-Law No. 17 of 2024). |
| Article 5 | Returns, records and documents are submitted in Arabic; the FTA may accept another language if an Arabic translation is provided on request, at the person's cost and responsibility for accuracy. |
| Articles 6–7 | Registrants must quote their TRN in all dealings, notify changes to registration data within 20 business days and apply to deregister under the tax law; a legal representative must notify its appointment within 20 business days and file the returns; licensing bodies notify the FTA of licences within 20 business days. |
| Article 10 | A voluntary disclosure is mandatory where a return, assessment or refund application understated payable tax or overstated a refund, optional where the error favoured the FTA, and errors without a tax difference are corrected by disclosure where the FTA so specifies or otherwise in a return. |
| Article 24 | The FTA issues an administrative penalty assessment, notified within five business days, for failures to keep records, provide Arabic documents, register or deregister on time, report changes, file returns or pay tax on time, and for incorrect returns, voluntary disclosures and audit obstruction; amounts are set by Cabinet decision. |
| Article 25 | Tax evasion, including deliberate non-payment, understating revenue to stay below thresholds, collecting tax while unregistered or deliberately reducing due tax, is punished by imprisonment and a fine of one to three times the evaded tax; false information, concealing or destroying records or obstructing the FTA carries imprisonment or a fine up to AED 1,000,000; participants are jointly liable for the tax and penalties. |
| Articles 28–29 | A person may request review of a tax assessment, or reconsideration of any FTA decision, within 40 business days of notification; the FTA decides within 40 business days and notifies within five; a review and a reconsideration cannot run on the same assessment at once. |
| Articles 30–33 | Objections go to the Tax Disputes Resolution Committee within 40 business days of the reconsideration decision and are inadmissible without a prior reconsideration request or full payment of the disputed tax; the Committee decides within 20 business days and its decision is final where tax and penalties do not exceed AED 100,000. |
| Article 36 | Either side may appeal the Committee's decision to the competent court within 40 business days; the court rejects a person's appeal without proof of full payment of the tax and settlement of at least 50% of the penalties in cash or by approved bank guarantee. |
| Article 38 | A refund of a credit balance must be applied for within five years of the end of the tax period in which the excess payment, return, disclosure, assessment or other event giving rise to it occurred. |
| Article 46 | As amended from 1 January 2026, the FTA may not audit or assess after five years from the end of the tax period, except within four years of an audit notice given in time, one year of a fifth-year voluntary disclosure, two years of a fifth-year refund application, or 15 years in cases of tax evasion or failure to register; no voluntary disclosure may be filed after five years. |
| Article 47 | Payable tax and administrative penalties of which the taxable person has been notified do not lapse with time, and the FTA may claim them at any time. |
Article 24 lists the breaches that attract administrative penalties, with the amounts in Cabinet Decision No. 40 of 2017 (VAT and excise) and Cabinet Decision No. 75 of 2023 (corporate tax). Article 25 makes tax evasion a crime: imprisonment and a fine of between one and three times the evaded tax, or either; deliberately not paying a penalty carries a fine of one to three times the penalty; false information, destroying records, stealing FTA documents or obstructing FTA staff carries imprisonment or a fine up to AED 1,000,000, rising to the evasion scale where evasion results. Participants are jointly liable, reoffending within five years aggravates, and the court may order publication of the judgment at the offender's cost.
Every penalty reconsideration, voluntary disclosure and audit response we prepare for clients runs on this law's clocks, and the 40-business-day windows are the ones we diarise first when a client forwards an FTA notification. The dispute ladder is unforgiving: a client who skips the reconsideration request or has not paid the disputed tax in full cannot get to the Committee, and cannot reach court without also settling half the penalties, so we price those cash requirements into the advice before recommending a challenge. On the compliance side, the 20-business-day duty to report changes catches clients who change their licence activity, address or manager without telling the FTA, so our corporate secretarial team raises the EmaraTax amendment alongside the free zone filing. The 2026 rewrite of Article 46 now gives one five-year limitation rule across corporate tax, VAT and excise, with 15 years where a client never registered, which is the risk we flag to companies that let registration slip.
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
Tax Procedures Executive Regulation
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 docu…
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…
Excise Tax Law
Imposes excise tax on goods the Cabinet designates as excise goods (tobacco, energy and carbonated drinks, sweetened drinks, electronic smoking devices and liquids) on th…
E-Invoicing System Decision
Defines the scope of the Electronic Invoicing System: every person conducting business in the UAE must issue and transmit electronic invoices and credit notes through an …
Tax Penalties Amendment (2025)
Amends the definitions in Article 1 and replaces Tables 1 and 3 of the tax penalties decision, restating the penalties for tax procedures and VAT violations with effect f…
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