UAE VAT Administrative Penalties: Cabinet Decision 40 of 2017 (As Amended) Explained

by Auditor A | May 30, 2026 | English Topics

UAE VAT administrative penalties — tax consultant reviewing FTA penalty notice — Abdelhamid & Co Sharjah

UAE VAT administrative penalties are imposed by the Federal Tax Authority under Cabinet Decision No. 40 of 2017 (as amended) for breaches of the Tax Procedures Law, the VAT Law and the Excise Tax Law. Penalties are set out in attached schedules and a person retains the right to object under Federal Decree-Law No. 28 of 2022. Abdelhamid & Co (MOE LC0106-01, FTA TAN 30003958) helps Dubai and Sharjah businesses manage exposure.

What Cabinet Decision 40 of 2017 Covers

The decision defines administrative penalties as monetary amounts imposed by the Federal Tax Authority for breaching the Tax Procedures Law or the relevant tax law. It contains three schedules: penalties relating to the Tax Procedures Law, the Excise Tax Law (effective 1 October 2017), and the VAT Law (effective 1 January 2018). The framework has since been amended, including by Cabinet Decision No. 49 of 2021, which reduced and restructured many penalties, and later amendments.

Our VAT & Excise Tax services help businesses understand and reduce penalty risk.

Key Facts on Administrative Penalties

Item Detail
Governing law Cabinet Decision No. 40 of 2017, as amended (incl. CD 49 of 2021)
Imposed by Federal Tax Authority (FTA)
Scope Tax Procedures Law, Excise Tax Law, VAT Law
VAT schedule effective 1 January 2018
Objection route As provided in Federal Decree-Law No. 28 of 2022 on Tax Procedures

How the Penalty System Works

Penalties cover failures such as not keeping required records, late tax registration, late filing of returns, late payment of due tax, and errors corrected through voluntary disclosure. Importantly, paying an administrative penalty does not relieve a person of the underlying tax due. The Cabinet may add, remove or amend penalties, and the FTA applies them based on the nature and timing of the breach.

Methodology — Reducing Penalty Exposure

1. Register for VAT on time and keep accounting records as required by law.
2. File every VAT return and pay due tax within the deadlines.
3. Use voluntary disclosure to correct errors before the FTA identifies them.
4. Run periodic compliance reviews to catch issues early.
5. Where a penalty is disputed, file a reconsideration request within the legal timeframe.

Common Mistakes and Risks

Frequent triggers include missing the registration threshold deadline, late or non-filing, underpaying tax, and poor record-keeping. Because penalties can accrue per return and per period, delays escalate the total quickly. Assuming a penalty is final is another error — many decisions can be challenged through reconsideration and the objection process.

Why Choose Abdelhamid & Co

We are a licensed UAE firm (MOE LC0106-01, FTA TAN 30003958) with FTA-registered tax agents and bilingual support. We help Dubai and Sharjah businesses prevent penalties, prepare voluntary disclosures, and challenge unjustified penalties on a fixed-fee basis. See our Tax Agency service.

Frequently Asked Questions

Who imposes VAT administrative penalties in the UAE?

The Federal Tax Authority imposes administrative penalties under Cabinet Decision No. 40 of 2017, as amended, for breaches of the Tax Procedures Law, the VAT Law and the Excise Tax Law.

Does paying a VAT penalty cancel the tax I owe?

No. Cabinet Decision No. 40 of 2017 makes clear that paying an administrative penalty does not relieve you of the underlying tax due. Both the tax and the penalty remain payable.

Can I object to a UAE VAT administrative penalty?

Yes. You may object to administrative penalties following the procedures in Federal Decree-Law No. 28 of 2022 on Tax Procedures, which can include a reconsideration request to the FTA and further objection steps.

Were UAE VAT penalties reduced after 2017?

Yes. Cabinet Decision No. 49 of 2021 amended the penalty framework, reducing and restructuring many administrative penalties, with later amendments also affecting the schedules.

Related Services

Contact Us

To manage or challenge VAT penalties, contact Abdelhamid & Co in Sharjah on 00971065610040 or use our contact page. Verify the law with the Federal Tax Authority and the Ministry of Finance.

Abdelhamid M. Abdelhamid
Partner & Managing Director
(UAECA, IACPA & VCD)
Emirates Association for Accountants & Auditors - EAAA Fellow Member - Reg. No.: 124
International Arab Society of Certified Accountants - IASCA Fellow Member - Reg. No.: 1361
Ministry of Economy Working-Auditors Record - Reg. No.: 956
FTA Tax Agent - TAAN No.: 20033908
Mobile: 009710507948028
Direct Phone: 00971065289414
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Abdelhamid & Co. Certified Public Accountants & Auditors L L C SP
Ministry of Economy "Local Auditors Record." Registration No.: LC0106-01
TAN: 30003958
Phone: 00971065610040

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