UAE government entities tax disputes are organised by Cabinet Decision No. 12 of 2025, which sets objection and appeal procedures for government entities in VAT disputes from their sovereign activities. Objections go to the Tax Disputes Resolution Committee. Abdelhamid & Co (MOE LC0106-01, FTA TAN 30003958) advises on UAE tax dispute procedure in Dubai and Sharjah.
What Cabinet Decision 12 of 2025 Covers
The decision regulates objection and appeal procedures in VAT disputes where government entities are a party, in respect of activities they carry out in a sovereign capacity. It works alongside Federal Decree-Law No. 28 of 2022 on Tax Procedures, Cabinet Decision No. 23 of 2018 (which formed the Tax Disputes Resolution Committees), and Cabinet Decision No. 74 of 2023 (the Executive Regulation of the Tax Procedures Law).
Our VAT & Excise Tax services support entities navigating these procedures.
Key Facts on the Procedure
| Item | Detail |
|---|---|
| Governing law | Cabinet Decision No. 12 of 2025, under FDL No. 28 of 2022 |
| Committee | Tax Disputes Resolution Committee (formed under CD No. 23 of 2018) |
| Objection deadline | 40 business days from notification of the FTA's reconsideration decision |
| Committee decision | Within 20 business days of receiving the objection |
| Finality threshold | Committee decision is final where total tax and penalties do not exceed AED 100,000 |
How the Process Works
A government entity first files a reconsideration request with the Federal Tax Authority. If dissatisfied with the FTA's decision, it submits an objection to the competent department (within the Ministry of Justice) within 40 business days of notification. The objection is not accepted if no reconsideration was filed first, or if it is late. Notably, government entities are not required to settle the full tax or penalty when objecting, until the committee decides.
The competent department forwards the objection to the committee within two business days. The committee studies and decides within 20 business days and notifies the parties within three business days. Where the total tax and administrative penalties do not exceed AED 100,000, the committee's decision is final.
Methodology — Managing a Government Tax Dispute
1. File the reconsideration request with the FTA first — it is a precondition.
2. Track the 40-business-day objection deadline from the FTA's decision.
3. Prepare the objection file with full legal and factual grounds.
4. Monitor the committee's 20-business-day decision window.
5. Assess whether the AED 100,000 finality threshold applies before considering further appeal.
Common Mistakes and Risks
The most damaging mistake is skipping the reconsideration stage, which makes the objection inadmissible. Missing the 40-business-day window is equally fatal. Entities also misjudge the AED 100,000 finality threshold, which determines whether the committee's decision can be appealed further. A reconsideration request handled correctly protects the later stages.
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 entities in Dubai, Sharjah and across the UAE prepare reconsiderations and objections within the legal deadlines, on a fixed-fee basis. See our Tax Agency service.
Frequently Asked Questions
What is the objection deadline for UAE government entities in tax disputes?
Under Cabinet Decision No. 12 of 2025, a government entity must file its objection with the competent department within 40 business days from being notified of the Federal Tax Authority's decision on the reconsideration request.
Must a government entity pay the tax before objecting?
No. For the purposes of accepting the objection, government entities are not required to pay the full tax or administrative penalty when objecting, until the committee decides — without prejudice to penalties that may arise under the Tax Procedures Law.
When is the tax committee's decision final for government entities?
The committee's decision is final where the total tax due and administrative penalties do not exceed AED 100,000. Above that amount, further appeal routes apply.
Can a government entity object without filing a reconsideration first?
No. The objection is not accepted if a reconsideration request was not first submitted to the Federal Tax Authority, or if the objection is filed after the deadline.
Related Services
- Reconsideration Requests — the mandatory first step
- VAT & Excise Compliance Review — strengthen your position before a dispute
- Voluntary Disclosure — correct errors proactively
- Insights — more UAE tax guidance
Contact Us
For help with a tax objection or appeal, contact Abdelhamid & Co in Sharjah on 00971065610040 or use our contact page. Verify procedure via the Federal Tax Authority and the Ministry of Justice.
Last reviewed: