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VAT and Excise Tax voluntary disclosure service UAE — correct errors in tax returns, reduce FTA penalties with Cabinet Decision No. 129 of 2025 — Abdelhamid & Co Sharjah

VAT and Excise Tax voluntary disclosure service in the UAE

The VAT and Excise Tax voluntary disclosure service allows registered taxable persons in the UAE to come forward and correct errors or omissions in previously submitted tax returns — before the Federal Tax Authority (FTA) identifies them. Submitting a voluntary disclosure proactively can significantly reduce penalties compared to those applied when errors are discovered by the FTA through audit or investigation. 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 file voluntary disclosures on your behalf directly via the EmaraTax portal.

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

Key facts — UAE voluntary disclosure penalty framework

VAT threshold: Voluntary disclosure required for errors of AED 10,000 or more; below AED 10,000 may be corrected in subsequent return
Excise Tax threshold: Any amount requires a voluntary disclosure
Penalty — before audit notification (Row 11): 1% monthly surcharge on tax difference only
Penalty — after audit notification (Row 12): 15% fixed penalty + 1% monthly penalty
Late payment surcharge (Row 9): 14% per annum on unpaid tax (effective 14 April 2026 under CD129/2025)
Payment deadline: 20 working days from voluntary disclosure submission or assessment receipt
Governing decisions: Cabinet Decision No. 40 of 2017 as amended by CD129 of 2025 (effective 14 April 2026)

Legal framework for voluntary disclosure in the UAE

The voluntary disclosure mechanism is established under:

  • Federal Decree-Law No. 8 of 2017 on VAT and its Executive Regulations — Article 8 governs VAT voluntary disclosures
  • Federal Decree-Law No. 7 of 2017 on Excise Tax and its Executive Regulations
  • Cabinet Decision No. 40 of 2017 on Administrative Penalties for Tax Violations, as amended by Cabinet Decision No. 49 of 2021, Cabinet Decision No. 108 of 2021, and most recently Cabinet Decision No. 129 of 2025 — effective 14 April 2026

The FTA publishes guidance on voluntary disclosures on its legislation page. Applications are submitted through the EmaraTax portal.

When is a voluntary disclosure required?

A voluntary disclosure must be filed when a taxable person discovers an error or omission in a previously submitted return that results in:

  • A tax difference of AED 10,000 or more (VAT) or any amount for Excise Tax
  • An underpayment of tax due to miscalculation of taxable supplies or deductible input tax
  • An incorrect claim for a zero-rate or exemption
  • Failure to account for a taxable supply or import
  • Errors in Excise Tax declarations including deregistration closing stock adjustments

Note: For VAT errors below AED 10,000 per return period, the correction may be made in the subsequent return rather than through a formal voluntary disclosure.

Administrative penalties applicable to voluntary disclosure

Under the consolidated penalty framework (Cabinet Decision No. 40 of 2017 as amended, including the amendments effective 14 April 2026 under Cabinet Decision No. 129 of 2025), the following penalties apply:

Late payment surcharge (Row 9)

Where unpaid tax remains outstanding, a late payment surcharge of 14% per annum applies, calculated as a monthly charge on the unpaid tax balance. This applies from the day following the payment due date. For voluntary disclosures, the payment due date is 20 working days from the date of submission; for tax assessments, it is 20 working days from the date of receipt.

Voluntary disclosure filed before FTA audit notification (Row 11)

Where the taxable person submits a voluntary disclosure before being notified of an FTA audit, the applicable penalty is a monthly surcharge of 1% on the tax difference, calculated from the day after the due date of the relevant return until the date of voluntary disclosure submission or tax refund request.

No voluntary disclosure filed before FTA audit notification (Row 12)

Where the taxable person fails to submit a voluntary disclosure before being notified of an FTA audit, two penalties apply simultaneously:

  • Fixed penalty: 15% of the tax difference
  • Monthly penalty: 1% of the tax difference per month or part thereof

The key takeaway: filing a voluntary disclosure before FTA audit notification avoids the 15% fixed penalty entirely and results in a significantly lower total exposure. Acting promptly after discovering an error is critical.

Our VAT and Excise Tax voluntary disclosure services

1. Error identification & tax impact assessment

We review your previously submitted VAT and Excise Tax returns, supporting documentation, and accounting records to identify errors, omissions, or incorrect classifications. We calculate the precise tax difference, the applicable penalties, and the total exposure to give you a clear picture before proceeding.

2. Voluntary disclosure report preparation

We prepare a technically accurate voluntary disclosure report in accordance with FTA requirements, clearly documenting the nature of the error, the corrected tax position, and the additional tax due. Where relevant, we also prepare supporting schedules and amended workings.

3. Submission via EmaraTax

As licensed FTA Tax Agents, we submit the voluntary disclosure on your behalf directly through the EmaraTax portal, ensuring all required fields, attachments, and supporting documentation are correctly provided.

4. FTA correspondence & penalty negotiation support

We handle all subsequent FTA correspondence, respond to any queries raised during the review, and assist with penalty reconsideration requests if appropriate. Where disputes arise, we can escalate to a forensic tax dispute report.

Why choose Abdelhamid & Co for VAT voluntary disclosure?

  • Licensed by the UAE Ministry of Economy — Local Auditors Record No. LC0106-01
  • Licensed FTA Tax Agent — TAN: 30003958 | TAAN: 20033908
  • 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
  • Up-to-date knowledge of the penalty framework including Cabinet Decision No. 129 of 2025 (effective 14 April 2026)
  • Full handling of FTA correspondence and follow-up
  • Forensic-grade documentation to support penalty minimisation
  • Bilingual team — Arabic and English
  • Transparent, fixed-fee engagements

Frequently asked questions — UAE VAT voluntary disclosure

What is the difference between a voluntary disclosure and a tax return amendment?

A voluntary disclosure is the formal mechanism to correct errors in a previously filed and accepted return. A tax return can be amended before it is accepted by the FTA. Once accepted, corrections must be made through the voluntary disclosure process via EmaraTax.

Is it better to file a voluntary disclosure before an FTA audit?

Yes — and critically so. Filing before FTA audit notification avoids the 15% fixed penalty on the tax difference entirely (Row 12 of the penalty schedule). If the FTA notifies you of an audit before you file, the 15% fixed penalty applies in addition to the 1% monthly penalty. Acting immediately upon discovering an error is the most cost-effective approach.

What is the late payment surcharge rate under the new 2025 amendments?

Under Cabinet Decision No. 129 of 2025 (effective 14 April 2026), the late payment surcharge is 14% per annum, applied as a monthly charge per month or part thereof on the unpaid tax balance, from the day following the payment due date. Payment is due within 20 working days of voluntary disclosure submission or tax assessment receipt.

How long do I have to file a voluntary disclosure?

There is no hard deadline, but the 1% monthly penalty on the tax difference accrues from the day after the original return due date until the date of disclosure. The longer you wait, the higher the total penalty exposure. Filing as soon as an error is discovered minimises total cost.

Does a voluntary disclosure apply to both VAT and Excise Tax?

Yes. The voluntary disclosure mechanism applies to both VAT and Excise Tax returns. Both are filed through the EmaraTax portal. The penalty framework under the consolidated Cabinet Decision (as amended by Decision No. 129 of 2025) applies to both taxes.

Can a licensed FTA Tax Agent file a voluntary disclosure on my behalf?

Yes. As licensed FTA Tax Agents, we can prepare and submit voluntary disclosures on your behalf via EmaraTax, handle all FTA correspondence, and manage the process from identification through to resolution.

What happens after a voluntary disclosure is submitted?

The FTA reviews the voluntary disclosure and issues an assessment confirming the additional tax and applicable penalties. The tax and penalties must be paid within 20 working days of receiving the assessment. We assist with any queries raised during the review and with the reconsideration process if needed.

Contact us for VAT voluntary disclosure 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)

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 — 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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Email: info@abdelhamidcpa.com

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