An FTA reconsideration request allows taxpayers in the UAE to formally challenge any decision issued by the Federal Tax Authority, including decisions related to Corporate Tax, VAT, Excise Tax, and administrative penalties. Under Article 29 of Federal Decree-Law No. 28 of 2022 on Tax Procedures, you must file your request within 40 business days of notification.
To preserve your right to appeal, the reconsideration request must be properly reasoned, supported by documentary evidence, and submitted through the official EmaraTax portal.
When You Can File an FTA Reconsideration Request
Article 29 of Federal Decree-Law No. 28 of 2022 on Tax Procedures provides the legal basis for submitting an FTA reconsideration request. The law permits any person to request the Authority to reconsider a decision issued against them.
An FTA reconsideration request may apply to decisions involving:
Corporate Tax
- Administrative penalties
- Tax assessments
- Registration determinations
- Deregistration decisions
Value Added Tax (VAT)
- Late filing penalties
- Late payment penalties
- VAT assessment adjustments
- Registration refusals
Excise Tax
- Assessment disputes
- Compliance penalties
- Registration decisions
Administrative Penalties Under the Tax Procedures Law
- Failure to maintain records
- Failure to submit tax returns
- Violations identified during audits
The law allows reconsideration of any decision or part of a decision. However, if the dispute concerns a tax assessment itself, Article 28 requires filing a Tax Assessment Review Request first. Filing the incorrect procedural route may invalidate your challenge.
Meet the 40 Business Day Deadline for an FTA Reconsideration Request
The reconsideration framework under UAE law is strictly time-bound. Missing a statutory deadline can permanently close your right to challenge an FTA decision. Understanding how the 40 business day rule operates is essential before preparing your submission.
Reconsideration Request Filing Window
You must submit your reconsideration request within 40 business days from notification of the decision.
The notification date determines when the statutory clock begins. Always retain the official communication showing the date of receipt.
FTA Decision Timeline
Under Article 29 of Federal Decree-Law No. 28 of 2022:
- The FTA must issue its decision within 40 business days of receiving the request.
- The Authority must notify you within 5 business days of issuing the decision.
Under Cabinet Decision No. 74 of 2023, the FTA may extend its internal decision period where justified.
Deadline Extensions Under FTA Decision No. 1 Of 2025
The FTA clarified acceptable extension cases in FTA Decision No. 1 of 2025.
Extensions may be granted where documentary proof demonstrates:
- Serious illness or accident of the authorized signatory
- Death of the authorized signatory or close family member
- Business disruption beyond reasonable control
- FTA system malfunction
- Force majeure circumstances
The same decision mandates rejection where delay resulted from:
- Lack of awareness of tax obligations
- Negligence of a tax agent
- Operational workload
- Complexity of the issue
This distinction is decisive. Unsupported explanations do not succeed.
Submit Your FTA Reconsideration Request Through EmaraTax
The Federal Tax Authority requires all reconsideration requests to be filed digitally through the official EmaraTax portal. Accurate submission is critical because procedural errors frequently lead to rejection. Taking time to prepare before logging in reduces avoidable mistakes.
Access the service at the official FTA Reconsideration Request page.
Confirm Authorized Representation
An FTA reconsideration request may be submitted by:
- The taxable person
- A registered tax agent
- A legal representative
- The representative member of a tax group
Non-registered advisers cannot legally file on behalf of others. Businesses that prefer not to manage the process internally often appoint a registered tax agent to handle documentation, portal submission, and FTA correspondence.
If you would like professional assistance managing your submission, contact TaxReady’s tax advisors for structured support throughout the reconsideration process.
Follow the Portal Navigation Steps
The official user manual outlines the process:
1. Log in to EmaraTax
2. Select the relevant taxable person
3. Click Other Services
4. Choose Reconsiderations
5. Select New Request
6. Enter the FTA decision reference number
Prepare Strong Legal and Documentary Grounds
An FTA reconsideration request succeeds or fails based on documentation quality. The Authority evaluates both factual accuracy and legal grounding. Weak evidence often results in rejection even when the underlying position is correct.
Reconsideration Request Required Supporting Documents
Attach:
Copy of the FTA decision
Proof of notification date
Authorization documents where applicable
Detailed factual explanation
Legislative references supporting your position
Address Filing or Reporting Errors
Many reconsideration requests arise from technical reporting inaccuracies, classification errors, or inconsistencies across Corporate Tax, VAT, or Excise submissions.
When prior filings contribute to the dispute, a structured financial review is essential. Professional Audit Support Services can help validate accounting treatment, reconcile records, and strengthen supporting documentation before submission.
Maintain Organized Financial Records
Clear financial records strengthen evidentiary credibility during FTA review. Businesses supported by structured Bookkeeping & Accounting Services maintain documentation that withstands scrutiny during audits or reconsideration proceedings.
Disorganized documentation weakens otherwise valid legal arguments.
What Happens After You Submit an FTA Reconsideration Request?
Once submitted, the FTA conducts an internal review of your reconsideration request. The outcome determines whether escalation becomes necessary. Understanding possible decisions helps you plan next steps strategically.
The FTA may:
- Approve the request fully
- Approve part of the request
- Reject the request
Partial approvals occur when only specific components of the decision are incorrect.
If rejected, escalation becomes possible.
File an Objection Before the Tax Disputes Resolution Committee
If the FTA rejects your reconsideration request, UAE law permits escalation to the Tax Disputes Resolution Committee. This stage is more formal and carries strict admissibility conditions. Filing correctly is essential to preserve your right to continue the dispute.
Under Article 30 of Federal Decree-Law No. 28 of 2022 on Tax Procedures, you may file an objection within 40 business days of notification of the reconsideration decision.
An objection is inadmissible if:
- You did not first file reconsideration
- The disputed tax amount remains unpaid
- The objection is filed late
The Committee generally decides within 20 business days, subject to lawful extension under Executive Regulations. Because this stage determines whether the dispute may proceed further, financial readiness and procedural accuracy are critical before filing.
Prepare For Court Appeal Requirements Under UAE Law
Court appeal represents the final escalation stage within the UAE tax dispute framework. However, not all disputes qualify for judicial review. The law imposes strict monetary thresholds and financial prerequisites before a court will admit the case.
Under Article 33 of Federal Decree-Law No. 28 of 2022, you may appeal to the competent court only if the total disputed tax and administrative penalties exceed AED 100,000.
Financial Admissibility Requirements
Before filing a court appeal, you must:
- Pay the full disputed tax amount
- Pay at least 50 percent of administrative penalties, or
- Provide a bank guarantee in favor of the Federal Tax Authority
Failure to satisfy these conditions results in automatic dismissal of the appeal.
Understand Court Appeal Admissibility And Cost Exposure
These payment requirements often influence whether escalation is commercially viable. Businesses must assess liquidity impact before proceeding.
In higher-value disputes, structured financial analysis can materially strengthen court submissions. Companies facing complex accounting treatment challenges often rely on professional services to validate documentation before entering litigation.
Because judicial escalation involves additional cost and time, careful evaluation is essential before filing.
Assess Strategic Risk Before Escalating Further
Escalation beyond reconsideration involves financial exposure and procedural complexity. Not every rejected reconsideration justifies further appeal. A structured risk assessment ensures that escalation aligns with commercial realities.
Consider:
Probability of success
Financial exposure
Security payment obligations
Duration of proceedings
Professional costs
If your dispute highlights broader compliance weaknesses, reviewing your Corporate Tax obligations may prevent similar issues in future periods. Structured support through Corporate Tax Filing Services can help ensure accurate reporting and reduce exposure to future penalties.
Addressing underlying filing gaps early often reduces the likelihood of repeat disputes.
Prepare Your FTA Reconsideration Request With Confidence
An FTA reconsideration request requires more than meeting a deadline. It demands clear reasoning, complete documentation, and procedural accuracy. Even small technical errors can weaken a strong case.
You have a limited window to act, and the quality of your submission directly impacts the outcome. Structured preparation improves clarity, credibility, and compliance with FTA requirements.
If your dispute involves complex documentation or financial review, our Audit Support Services can help ensure your evidence meets procedural standards before submission.
Contact TaxReady’s tax advisors today.
Frequently Asked Questions
What is the Deadline to File an FTA Reconsideration Request?
The deadline to file an FTA reconsideration request is 40 business days from the date of notification of the FTA decision. This requirement is set out in Article 29 of Federal Decree-Law No. 28 of 2022 on Tax Procedures.
How Do I Submit an FTA Reconsideration Request Online?
To submit an FTA reconsideration request online, log in to the EmaraTax portal, select “Other Services,” choose “Reconsiderations,” and submit a “New Request” using the official FTA decision reference number.
Can I Appeal if the FTA Rejects My Reconsideration?
Yes. If the FTA rejects your reconsideration request, you may file an objection before the Tax Disputes Resolution Committee within 40 business days of receiving the reconsideration decision.
Do I Need to Pay Tax Before Filing an Objection?
Yes. You must pay the full disputed tax amount before filing an objection with the Tax Disputes Resolution Committee. Failure to do so makes the objection inadmissible under Federal Decree-Law No. 28 of 2022.
Is Payment Required Before Court Appeal?
Yes. Before filing a court appeal, you must pay the full tax amount and at least 50 percent of administrative penalties, or provide a bank guarantee in favor of the Federal Tax Authority.
What Happens if I Miss the 40 Business Day Deadline?
If you miss the 40 business day deadline, your FTA reconsideration request will likely be rejected unless you qualify for a deadline extension under FTA Decision No. 1 of 2025 and provide supporting documentary evidence.
