Corporate Tax Reconsideration in the UAE

What Is Corporate Tax Reconsideration?

Corporate tax reconsideration is a statutory remedy available to taxpayers who disagree with a specific decision issued by the FTA. Through this process, the taxpayer may request the FTA to reassess its decision based on legal grounds, factual inaccuracies, or misinterpretation of applicable tax provisions.

Successful reconsideration requests are typically grounded in clear evidence, documented facts, and precise application of the law rather than general disagreement.

If the FTA finds merit in the request, it may amend, partially revise, or fully withdraw the original decision. This mechanism allows disputes to be resolved efficiently without immediately escalating to formal litigation.

This early-stage remedy often determines the direction and strength of any subsequent dispute resolution process.

Who Can Submit a Reconsideration Request?

A reconsideration request may be filed by:

• The taxable person directly affected by the FTA decision
• An authorized legal representative
• A registered tax agent appointed to act on behalf of the taxpayer

In the case of a tax group, only the representative member is permitted to submit the reconsideration request.

Submitting the request through the correct authorized party is essential to avoid procedural rejection.

Time Limit for Filing a Reconsideration

A reconsideration request must be submitted within 40 business days from the date on which the FTA issues the relevant decision.

Failure to meet this deadline generally results in the loss of the right to request reconsideration, making timely action critical.

Once this window lapses, the taxpayer is typically forced into formal dispute channels with higher cost and complexity.

Decisions Eligible for Reconsideration

Only formal and specific decisions issued by the FTA to a particular taxpayer may be challenged through reconsideration, including:

• Corporate tax assessments
• Administrative penalties
• Other enforceable tax decisions addressed to a specific taxable person

General guidance, clarifications, or informal responses issued by the FTA are not eligible for reconsideration.

Understanding whether a communication qualifies as a “decision” is a key preliminary assessment before filing.

Reconsideration Filing Process

The reconsideration process involves the following steps:

1. Submission of the request through the EmaraTax portal
2. Detailed explanation of the grounds for disagreement
3. Upload of all supporting documents and evidence
4. Review and evaluation by the FTA

Once a complete application is submitted, the FTA generally issues its decision within 45 business days.

In practice, the review timeline depends heavily on the quality, clarity, and completeness of the submission, as well as any follow-up queries raised by the FTA.

Why Corporate Tax Reconsideration Matters?

Filing a reconsideration request offers several key benefits:

• Potential reduction or cancellation of penalties or assessments
• Opportunity to correct factual or legal errors
• Cost-effective dispute resolution without immediate legal proceedings
• Improved confidence in regulatory fairness and transparency

It also allows businesses to address issues early, before matters escalate into audits, enforcement actions, or prolonged disputes.

What If the Reconsideration Is Rejected?

If the FTA rejects the reconsideration request, the taxpayer may escalate the matter to the Tax Dispute Resolution Committee (TDRC), which serves as an independent adjudicating authority for tax disputes in the UAE.

The quality of the reconsideration submission often directly impacts the strength of any subsequent appeal before the TDRC.

How German Fintax Consultancy Helps

Our corporate tax specialists provide end-to-end support, including:

• Evaluation of FTA decisions and feasibility assessment
• Drafting legally sound reconsideration submissions
• Documentation review and evidence structuring
• Representation before the FTA and follow-up coordination
• Strategic guidance for escalation, if required

We focus on delivering clear, compliant, and defensible submissions that improve the likelihood of a favorable outcome.

Each case is assessed for legal merit before filing, ensuring that reconsideration is pursued only where it adds strategic value.