Corporate Tax Appeals & TDRC Representation in the UAE

Understanding the Corporate Tax Appeal Process in the UAE

The UAE tax dispute framework follows a multi-stage process under the Tax Procedures Law and related regulations, applicable across federal taxes including Corporate Tax and VAT.

1. Reconsideration Request; First Level of Appeal

Before approaching the TDRC, a taxpayer must first submit a Reconsideration Request to the FTA.

Key requirements:

• Must be filed within 40 business days from the date of notification of the FTA’s decision
• Must clearly outline legal and factual grounds of objection
• Must include complete supporting documentation
• Submitted via the FTA portal
• Failure to meet procedural requirements or deadlines may result in rejection of the reconsideration request

The FTA reviews the submission and issues a reconsideration decision. If the outcome remains unfavourable, the taxpayer may proceed to the next level.

A technically weak reconsideration request may significantly reduce the chances of success at the TDRC stage, making professional drafting critical.

2. Appeal to the Tax Dispute Resolution Committee (TDRC)

If dissatisfied with the FTA’s reconsideration decision, businesses may file an objection with the TDRC.

The TDRC is an independent committee operating under the supervision of the UAE Ministry of Justice. Each committee typically consists of:

• A judicial authority chairperson
• Two tax experts

This ensures technical accuracy and legal integrity in dispute resolution.

Important Conditions for Filing an Appeal:

• Appeal must be filed within 40 business days from the reconsideration decision
• All payable tax amounts must generally be settled before the appeal is accepted in accordance with statutory payment conditions under the Tax Procedures Law
• In certain cases, penalties must also be paid (subject to legal thresholds and conditions)
• The appeal must be filed with the competent TDRC based on jurisdiction

• Incomplete documentation or improper jurisdiction filing may result in procedural dismissal

Strategic preparation at this stage includes structured evidence presentation, revised tax computations (where applicable), and detailed legal reasoning aligned with Corporate Tax Law provisions and FTA guidance.

3. Judicial Escalation (Court Proceedings)

If the total disputed tax and penalties exceed AED 100,000, either party may escalate the matter to the UAE Federal Courts after the TDRC’s decision.

This may include:

• Federal Court of First Instance
• Court of Appeal
• Federal Supreme Court

Court escalation requires strong litigation preparation and procedural compliance.

At this stage, legal strategy, evidentiary structuring, and technical tax defense become critical to protect financial exposure and compliance standing.

Where applicable, applications for suspension of collection measures may be considered subject to statutory conditions.

Why Professional Representation Matters

Corporate tax disputes often involve:

• Complex technical tax interpretations
• Documentation inconsistencies
• Penalty mitigation arguments
• Procedural compliance deadlines
• FTA audit findings and assessment recalculations
• Interpretation of Corporate Tax Law provisions and Ministerial Decisions

At German Fintax Consultancy, we provide:

• Strategic objection drafting
• Evidence preparation and tax computation review
• Penalty mitigation advisory
• Full TDRC representation support
• Court escalation coordination
• Technical reassessment modelling and financial reconstruction where required
• Structured defense aligned with UAE Corporate Tax Law and Tax Procedures Law

Our approach ensures that your case is legally sound, technically accurate, and strategically positioned.

Protect Your Business with Strategic Tax Representation

Corporate tax disputes can impact cash flow, compliance standing, and business reputation. A proactive, well-structured appeal strategy is essential.

If your business has received a tax assessment or penalty decision, contact German Fintax Consultancy for professional guidance and structured representation before the TDRC.

Request a structured appeal case assessment immediately to protect your rights within the 40-business-day statutory deadline.