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VAT and Excise Tax reconsideration requests service UAE — challenge FTA tax assessments, penalties and refund rejections via EmaraTax — licensed FTA Tax Agent Abdelhamid & Co Sharjah

VAT and Excise Tax reconsideration requests service in the UAE

A VAT and Excise Tax reconsideration request is a formal application submitted to the Federal Tax Authority (FTA) challenging a tax decision — such as a tax assessment, penalty imposition, or refund rejection — that a taxable person believes to be incorrect. It is the first mandatory step in the UAE tax dispute process before escalating to the Tax Disputes Resolution Committee (TDRC) or the courts. At Abdelhamid & Co. Certified Public Accountants & Auditors L L C SP, we are licensed by the UAE Ministry of Economy (Local Auditors Record No. LC0106-01) and registered as a licensed FTA Tax Agent (TAN: 30003958 | TAAN: 20033908). We prepare and submit reconsideration requests on your behalf directly via the EmaraTax portal.

This service is part of our broader UAE VAT and excise tax services. It is closely linked to our forensic audit report for FTA tax disputes and our voluntary disclosure service. Learn more about our firm and our team.

Legal framework for FTA reconsideration in the UAE

The reconsideration process is governed by:

  • Federal Decree-Law No. 28 of 2022 on Tax Procedures (replacing Federal Law No. 7 of 2017) — Articles governing the right to object and appeal FTA decisions
  • Federal Decree-Law No. 8 of 2017 on VAT and its Executive Regulations
  • Federal Decree-Law No. 7 of 2017 on Excise Tax and its Executive Regulations
  • Cabinet Decision No. 40 of 2017 on Administrative Penalties, as amended by Cabinet Decision No. 49 of 2021, No. 108 of 2021, and Cabinet Decision No. 129 of 2025 (effective 14 April 2026)

The FTA publishes the applicable legislation and procedures on its legislation page. All submissions are made through the EmaraTax portal.

Key facts — FTA reconsideration requests UAE

Filing deadline: 40 business days from FTA decision notification
FTA response deadline: 40 business days from receiving the request
TDRC escalation deadline: 40 business days from reconsideration decision
Late payment surcharge: 14% per annum (CD 129/2025, effective 14 April 2026)
Governing law: Federal Decree-Law No. 28 of 2022, Article 29
Our TAAN: 20033908 | TAN: 30003958

The UAE tax dispute process — 4 stages

The UAE tax dispute process has four formal stages. Reconsideration is the mandatory first step:

  • Stage 1 — Reconsideration Request: Filed with the FTA via EmaraTax within 40 business days of receiving the FTA decision. The FTA must respond within 40 business days. This step is mandatory before any further appeal.
  • Stage 2 — Tax Disputes Resolution Committee (TDRC): If the reconsideration response is unsatisfactory or no response is received, the dispute can be escalated to the TDRC within 40 business days of the FTA’s reconsideration decision.
  • Stage 3 — Court of First Instance: If the TDRC decision is unsatisfactory, the matter may be referred to the competent court.
  • Stage 4 — Court of Appeal and above: Further judicial appeal stages are available under UAE civil procedure law.

As licensed FTA Tax Agents, we represent clients at Stages 1 and 2. For Stages 3 and 4 we work alongside your legal counsel, providing the forensic accounting report required for court proceedings.

Decisions that can be subject to reconsideration

A reconsideration request can be filed against a range of FTA decisions, including:

  • Tax assessments — where the FTA has assessed additional VAT or Excise Tax
  • Administrative penalty decisions — imposed under Cabinet Decision No. 40 of 2017 and its amendments
  • VAT or Excise Tax refund rejections
  • Deregistration rejections or forced deregistration decisions
  • Decisions relating to tax group applications or modifications
  • Any other formal decision issued by the FTA that affects a taxable person’s tax position

Our VAT and Excise Tax reconsideration request services

1. Decision review & legal grounds assessment

We review the FTA decision in detail — whether it is a tax assessment, penalty notice, or refund rejection — and assess the legal and technical grounds on which it can be challenged. We advise on the strength of the reconsideration case and the likely outcome before committing to the process.

2. Reconsideration request preparation

We prepare a technically robust reconsideration request clearly setting out the legal basis under Federal Decree-Law No. 28 of 2022, the factual background, supporting evidence, and specific relief sought. Requests are prepared in both Arabic and English as required by the FTA.

3. Submission via EmaraTax

As licensed FTA Tax Agents, we submit the reconsideration request on your behalf directly through the EmaraTax portal within the 40 business day deadline, ensuring all required documents and supporting materials are correctly attached.

4. FTA response monitoring & TDRC escalation

We monitor the FTA’s response, advise on the outcome, and — if the reconsideration decision is unsatisfactory — prepare and file the escalation to the Tax Disputes Resolution Committee (TDRC) at Stage 2. Where court proceedings are required at Stages 3 and 4, we prepare the forensic tax dispute report required by the court.

5. Post-dispute compliance advisory

Following the resolution of your dispute, we advise on any corrective actions required to prevent recurrence — including adjustments to your VAT return filing process, internal controls, record-keeping practices, and ongoing compliance review arrangements to strengthen your position against future FTA scrutiny.

Our methodology — how we deliver the reconsideration service

Our structured approach ensures accuracy, compliance, and timely action at every stage:

  • Step 1 — Initial case assessment: We review the FTA decision, assess the merits of challenging it, and advise on the legal grounds, probability of success, and financial exposure before engagement.
  • Step 2 — Evidence gathering and documentation: We collect all relevant invoices, contracts, accounting records, prior returns, and FTA correspondence to build the evidentiary foundation for the request.
  • Step 3 — Reconsideration request drafting: We prepare the formal request in Arabic and English, clearly articulating the legal basis under Federal Decree-Law No. 28 of 2022, the factual errors in the FTA decision, and the specific relief sought.
  • Step 4 — Submission and deadline management: We file the request via EmaraTax within the 40 business day deadline, with all supporting documents properly attached and indexed.
  • Step 5 — Follow-up, escalation, and resolution: We monitor the FTA response, handle all correspondence, and — if needed — escalate to the TDRC or prepare the forensic report for court proceedings.

Why choose Abdelhamid & Co for FTA reconsideration requests?

  • Licensed FTA Tax Agent — TAN: 30003958 | TAAN: 20033908
  • Licensed by the UAE Ministry of Economy — Local Auditors Record No. LC0106-01
  • UAECA — UAE Certified Accountant
  • IACPA — International Association of Certified Public Accountants
  • EAAA Fellow — Registration No. 124
  • IASCA Fellow — Registration No. 1361
  • Direct submission via EmaraTax on your behalf
  • Full representation at Stages 1 and 2 of the UAE tax dispute process
  • Up-to-date knowledge of the penalty framework including Cabinet Decision No. 129 of 2025
  • Forensic accounting report preparation for court stages (3 & 4)
  • Bilingual team — Arabic and English (submissions in both languages)
  • Transparent, fixed-fee engagements with no hidden costs

Frequently asked questions — FTA reconsideration requests UAE

What is the deadline to file a reconsideration request with the FTA?

A reconsideration request must be submitted to the FTA within 40 business days of receiving the FTA decision being challenged. Missing this deadline may extinguish the right to challenge the decision at this stage.

Is a reconsideration request mandatory before going to the TDRC?

Yes. Under UAE Tax Procedures law, a reconsideration request to the FTA is the mandatory first step. The TDRC will not accept a dispute that has not first gone through the reconsideration process.

Does filing a reconsideration request suspend the payment obligation?

Filing a reconsideration request does not automatically suspend the obligation to pay the disputed tax or penalties. Late payment surcharges of 14% per annum (under Cabinet Decision No. 129 of 2025, effective 14 April 2026) continue to accrue on any unpaid amounts during the dispute process. We advise clients on the financial exposure at each stage.

How long does the FTA take to respond to a reconsideration request?

The FTA is required to issue its reconsideration decision within 40 business days of receiving the request. If no response is received within this period, the request may be deemed rejected for the purposes of escalating to the TDRC.

Can a licensed FTA Tax Agent represent me in the reconsideration process?

Yes. As licensed FTA Tax Agents (TAN: 30003958 | TAAN: 20033908), we can prepare, submit, and fully represent you in the reconsideration process via EmaraTax at Stage 1 and before the TDRC at Stage 2.

What if the reconsideration is rejected — what are my next steps?

If the FTA rejects the reconsideration request, the dispute can be escalated to the Tax Disputes Resolution Committee (TDRC) within 40 business days. If the TDRC decision is also unfavourable, the matter can be referred to the courts. We assist at every stage — including preparing the forensic tax dispute report required for court proceedings.

Can I challenge an administrative penalty imposed under Cabinet Decision No. 129 of 2025?

Yes. Administrative penalties imposed under Cabinet Decision No. 129 of 2025 (effective 14 April 2026) and its predecessors can be challenged via the reconsideration process under Federal Decree-Law No. 28 of 2022. We review the penalty notice, assess the grounds for challenge, and where legally justified, prepare and submit the reconsideration request to the FTA.

Related services

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Contact us for VAT reconsideration request services in the UAE

📞 Phone / WhatsApp: +971 50 794 8028
📞 Direct: +971 065 289 414
🌐 Office: Sharjah, Al Qasimia, Omran Tower, Office 302

Abdelhamid & Co. Certified Public Accountants & Auditors L L C SP — Licensed by the UAE Ministry of Economy (LC0106-01) | Licensed FTA Tax Agent (TAN: 30003958 | TAAN: 20033908)

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Abdelhamid M. Abdelhamid — Partner & Managing Director
Abdelhamid & Co. Certified Public Accountants & Auditors L L C SP
UAECA | IACPA | EAAA Fellow No. 124 | IASCA Fellow No. 1361
UAE Ministry of Economy — Local Auditors Record LC0106-01 | Working-Auditors Record No. 956
FTA Tax Agent — TAN: 30003958 | TAAN: 20033908
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Last reviewed: April 2026. Content reflects UAE law at date of review.


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