Cabinet Resolution No. (74) of 2023 on the Executive Regulations of Federal Decree-Law No. (28) of 2022 on Tax Procedures (tax law)

Article (1)  
Definitions  
 
The definitions set forth in Federal Decree -Law No. (28) of 2022, referred to hereinabove, 
shall be applicable  hereto ; while the following words and expressions shall bear the 
meanings  assigned t hereto respectively, unless the context requires otherwise :  
Decree -Law  : Feder al Decree -Law No. (28) of 2022, on Tax Procedures.  
Headquarters  : The business place of the Taxable P erson, or any othe r place 
in which they practice their business , store  goods or keep 
records.  
Assets  : Tangible and intangible assets, including machinery, 
equipment, goods … etc., which the FTA deems to be owned, 
leased out or used for  purposes related to the engagement in 
business activities by any Person.

Article (2)  
Recordkeeping  
1. Accounting  recor ds and commercial books shall include the following:  
a. Busi ness records and books in which payments, receipts, purchases, sales, 
revenues, expenses and  any other items required by the Tax Law or any other 
applicable law  are recorded , including without limitation  the following:  
1. Balance sheet and profit and loss  account s;  
2. Payrolls;  
3. Fixed assets records; and  
4. Inventory records and accounts (including quantities  and values) kept at 
the end of any relevant Tax Period , and inventory counting records of 
inventory lists.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  3 
 b. All documents supporting entries set out in accounti ng records and 
commercial books, including without limitation:  
1. Business c orrespondence, invoices, licenses and contracts; and   
2. Documents  containing details of any choice, assessment, determination or 
calculation made  by the Taxpayer pertaining to T ax affairs, including basis 
or method of such assessment, determination or calculation made.  
2. In addition to  the accounting records and commercial books referred to in Clause  
(1) above, the FTA may request any other information to verify the tax obligation s 
of the Pers on through a series of auditable documents, including the liability of 
such Person for registrat ion for the purposes of the Tax.

Article (3)  
Recordkeeping Period  
1. All accounting records, commercial books and information shall be kept in a way 
that enable FTA or any employee authorized  by it to verify the Tax obligations 
imposed on the relevant P erson for the subsequent periods, unless otherwise 
required by the Tax Law:   
a. For (5) years subsequent  to the relevant Tax Period for the Taxable Person;  
b. For (5) ye ars as of the expiry date of the calendar year during which the 
document i n question has been created for other non -taxable persons; and  
c. For (7) years as of the expiry date of the calendar year during which the 
document in question  has been created pertaining to land registers.  
2. In addition to the periods referred to in Clause (1) above, the Person shall keep the 
records and books for the following extra perio ds in the following cases:  
a. For extra (4) four  years or until a dispute is resolved, whichever is later, in case 
of a dispute be tween the FTA and the Person on the Person’s tax obligations;  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  4 
 b. For extra (4) four years if the Person is subject t o a tax audit that has not been 
completed;  
c. For extra (4) four years if the Person is notified that the FTA intends to carry 
out a tax audit before the expiry of the period set out in Clause (1) above;  or   
d. For extra one year, commencing from the da te of submitting the Voluntary 
Declaration, as for the Taxable Person that submits a Voluntary Declaration in 
the fifth year from the expiry  of the relevant Tax Period.  
3. Subject  to Clauses (1) and (2) above, a legal representative shall keep records and 
books of the Person he represen ts for one year, a s of the d ate on which such legal 
representation  expires.

Article (4)  
Method of Keeping  Accounting Records and Commercial Books  
1. Accounting records and commercial books shall be kept by any of the following 
means:  
a. Creating a register and keeping the original  supporting documen ts of entries 
mentioned therein; and   
b. Creating a register and keeping the information mentioned in  the original 
documents, subject to the following:  
1. The information mentioned in the reg ister must match t he data set out in 
the original document, and must be available  within the periods referre d 
to in article (3) above;  
2. The information  must be saved or stored in a photocopy  or electronic 
format, where a copy thereof can be extracted, within the period set by the 
FTA  pursuant to th e provisions of article (48) of the Decree -Law, so that it 
would be easily readable if the same is requested  by the FTA; and  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  5 
 3. The information must be saved or sto red in a manner that allows FTA to 
verify the Person’s tax obligations.  
2. The FTA may set rules for  keeping information set out in the accounting records 
and commercial books, and may set proper requirements  to ensure the availability 
of such information as if the original documents were kept.

Article (5)  
Language  
1. The FTA may accept the data, information, records and any oth er documents 
related to any Tax to be submitted to the FTA in English , and may  also , at is 
discretion, instruct the Person to translate any or all of the above into Arabic.  
2. The translation of a ny Tax Return, data, information, re cords, documents or other 
books into Arabic shall be duly certified pursuant to the law governi ng translation 
in the State, and shall be submitted to the FTA within the time limit set by it.

Article (6)  
Procedures of Tax Registration and Deregistration and Data Amendment  
1. A Tax Registration application shall be submitted to the FTA , as per the form and 
mechanism designated by the same. The FTA may determine any supporting 
documents to be submitted for such purpose.  
2. The FTA shall review the Tax Registration application, as per the rules adopted by 
the FTA  in this regard.  
3. The Tax Registration shall take place by assigning a Tax Registration Number to 
the applicant or reactivating the pervious Tax Registration Number if the applicant 
already has a suspended Tax Registration N umber.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  6 
 4. The Registered Person shall notify the FTA, as per the form and mechanism 
adopted by the FTA , within (20) twenty Business Days  of any change to data 
retained by the FTA , including:  
a. Name, address and email address.   
b. Activity registered in the Trade  License.   
c. Legal form and partnership contract as for consortiums, and memorandum of 
association or the equivalent.   
d. Nature of business of the Registered Person; and  
e. Address from which the Registered Person practices any business.  
5. A Tax deregistration ap plication shall be submitted to the FTA , as per the form and 
mechanism adopted by the same, and FTA may determine any supporting 
documents to be submitted for such purpose.  
6. The FTA shall review the Tax Deregistration application, as per the rules adopted 
by the same for such purpose.  
7. In cases the Registered Person fails to submit an application of Tax deregistration, 
the FTA may terminate their Tax Registration according to the controls and 
procedures set out in the Tax Law.  
8. The Tax deregistration shall take place by suspending the Tax Registration 
Number.  
9. The FTA shall notify the Person of their Tax Registration, deregistration,  or 
reactivation according to the mechanism adopted by the same in this regard.

Article (7)  
Obligations of Licensing Authorities in the State  
Government authorities in charge of granting licenses to Persons to engage in business 
shall, within (20) twent y Business Days from the date of issuing or renewing the License, Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  7 
 so notify the FTA, as per the mechanism determined by the FTA . The notification shall 
include the following:  
1. Name of licensee.   
2. Type, number and date for issuing the trade license.   
3. Registered address of licensee.   
4. Description of business activity;  
5. Data of owners, partners,  and directors; and  
6. Any other information required by the FTA .

Article (8)  
Legal Representative  
1. A Person appointed as a Legal Representative of a Taxable Person shall so notify 
the FTA, as per the mechanism determined by it, and shall attach with the 
notification an appropriate proof of his appointment. The notification shall 
include the following:  
a. Name and address of the Legal Representative.   
b. Name, address and Registration Number (if any) of the Taxable Person 
represented by the Legal Representative.   
c. Term of appointment in case of fixed term; and  
d. Responsibilities of the Lega l Representative.  
2. The FTA may request any extra information on the appointment of the Legal 
Representative, and may obtain such information from the Legal Representative, 
the relevant Taxable Person and any other Person to verify such appointment.  
3. When the FTA accepts the application for appointing the Legal Representative, the 
FTA shall, within (20) Business Days following the acceptance date, notify the 
Legal Representative  of the same .  
 Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  8

Article (9)  
Allocation of Payments and Credit Balance  
1. If the Taxable Person pays an amount to the FTA  without identifying Tax Type or 
Tax Period, FTA may allocate the amount or part thereof for paying any amounts 
payable to the FTA  for being owed by the Taxable Perso n, based on the order of 
maturity of such amounts to the FTA .  
2. If the payments received by the FTA , pursuant to Clause (1) above, exceed the 
current obligations of the Taxable Person, FTA may register such amount in excess 
as a credit balance against the T axable Person’s future obligations, unless the 
Taxable Person requests to refund the surplus amount pursuant to article (38) of 
the Decree -Law.  
3. The FTA may allocate the credit balance or part thereof for the payment of any 
amounts payable thereto owed by the Taxable Person, based on the order of 
maturity of such amounts to the FTA .  
4. The FTA shall notify the Taxable Person of the method of allocating the amounts 
and the credit balance according to Clauses (1) and (3) above.

Article (10)  
Submission of Voluntary Declaration  
1. Where the Taxable Person becomes aware that the Tax Return submitted to the 
FTA  or the Tax Assessment issued by the FTA  is inaccurate, which led to calculating 
the Payable Tax, pursuant to the Tax Law, less than required , the following shall 
be applicable:  
a. If the amount is more than (AED 10,000) ten thousand dirhams, they shall 
submit a Voluntary Declaration, within (20) twenty Business Days following 
the date they become aware of the error.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  9 
 b. If the amount is equal to (AED 10,000) ten thousand dirhams or less, they shall 
act as follows:  
1. If the Taxable Person is obliged to submit a Tax Return to the FTA , errors 
shall be corrected in the Tax Return for t he previous Tax Period whose 
submission has not been yet due, or in the Tax Return for the Tax Period in 
which the error has been detected, whichever is earlier.  
2. Submitting a Voluntary Declaration within (20) twenty Business Days 
from the date of being aw are of the error in the absence of a Tax Return 
through which they can correct the error, pursuant to Subclause (1) above.  
2. If the Taxpayer finds that the tax refund application submitted to the FTA  is 
inaccurate, which led to calculating the amount that w ould have been refundable 
under the Tax Law in excess to the accurate value, they shall submit a Voluntary 
Declaration to the FTA  within (20) twenty Business Days from the date of being 
aware of the error, unless the same is arising from an inaccurate Tax Return or Tax 
Assessment. In this case, the provisions of Clause (1) above shall be applicable.  
3. If the Taxpayer finds an error or omission in the Tax Return submitted to the FTA , 
with no difference in the Due Tax amount, they shall correct the error or su bmit a 
Voluntary Declaration, as determined by the FTA .  
4. For the purpose of implementing the provisions of this Article, the Voluntary 
Declaration shall be submitted according to the forms and the mechanism 
identified by the FTA .   
 
  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  10

Article (11)  
Means o f Notification  
1. The FTA shall serve a notice to the Person or their Tax Agent or Legal 
Representative, as the case may be, to the address registered with the same via any 
of the following means:  
a. Mail, registered mail, email or text messages on the mobile phone, smart 
applications or electronic systems of the FTA ;  
b. Posting on a prominent place at the Person’s Headquarters; or  
c. Any other means to be agreed on between the Person and the FTA.  
2. For the purpose of this Article, the registered address includes, w ithout limitation, 
the address provided by the Person to the FTA , the Person’s usual address or last 
place of residence or business known for the same.

Article (12)  
Tax Agent Registration Conditions and Controls  
1. A natural Person who desires to be registered in the Register of Tax Agents shall :  
a. Be a person of good conduct and reputation ;  
b. Have never been convicted of a felony or misdemeanor, even if he has been 
rehabilitated;  
c. Have the minimum level of the relevan t education and experience in taxation, 
accounting or law in any of the following forms:  
1. Career experience of not less than (3) three years acquired throughout the 
previous five years, and holding at least a bachelor or master degree 
accredited in taxatio n, accounting or law from an educational institution 
recognized by the competent authority in the State;  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  11 
 2. Career experience of not less than (3) three years acquired throughout the 
previous five years, and holding a bachelor or master degree accredited in any 
other field from an educational institution recognized by the competent 
authority in the State, in addition to a valid professional certificate from a 
recognized institution, as determined by the FTA ; and  
3. Career experience of not less than (5) five ye ars acquired throughout the 
previous eight years, and holding a bachelor or master degree accredited in 
any other field from an educational institution recognized by the competent 
authority in the State;  
d. Complete any necessary training, as determined by the FTA , and successfully pass 
any qualification tests, as determined by the FTA ;  
e. Master spoken and written Arabic or English;  
f. Have a professional liability insurance or be covered by the same under a 
professional liability insurance contract, commensurat e with the nature and 
business volume of the Tax Agent;  
g. Have a license or work for an entity having a license from the competent 
authority; and  
h. Not be a current member of the Committee.  
2. A legal Person that desires to be registered in the Register of Tax Agents must:  
a. Be licensed as an audit firm, tax office or law firm;  
b. Have a professional liability insurance or be covered by the same under a 
professional liability insurance contract, commensurate with the nature and 
business volume of the Tax Agent;  
c. Have one of partners or managers fulfilling all the conditions prescribed for a 
natural Person, as set out in Clause (1) above, supervising the services provided 
by the legal Person and not working for another legal Person or for its favour; and  
d. Fulfill any  additional conditions determined by the FTA .  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  12 
 3. An application for registration in the Register must be submitted to the FTA  according 
to the form and mechanism specified by the FTA .  
4. FTA may, before deciding on the application for registration in the register, request 
additional information from the applicant, and may request a personal interview with 
the natural Person, pursuant to Clause (1) above, or with partner/manager, pursuant 
to Paragraph (c) of Clause (2) above, as the case may be, or may inquire about the 
references and documents mentioned in the registration application.  
5. FTA shall provide for the provisions related to the procedures for registration of the 
Tax Agent and cont inuation, renewal, suspension or revocation of the registration.

Article (13)  
Procedures for Registration or Deregistration of the Tax Agent  
1. The FTA shall examine the applications for registration in the Register, and shall 
decide on the application or may request additional information within (15) 
fifteen business days following the date of receipt.  
2. If the FTA requests additional information pursuant to Clause (1) abov e, it shall 
decide on the application within (15) fifteen Business Days from the date of 
receiving such additional information.  
3. If the FTA approves an application for registration in the Register, it shall so notify 
the applicant within (5) five Business Days and request the payment of the due 
fees.  
4. The due fees shall be paid pursuant to Clause (3) above within 20 Business Days 
from the date of Notification of the approval. If the due fees are not paid within 
such time limit, the application shall be null  and void.  
5. The FTA shall register the Person in the Register of Tax Agents within (5) five 
Business Days following the date of pay ment of the fees.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  13 
 6. The FTA may reject an application for registering the Person in the Register in any 
of the following cases :  
a. If the Person fails to fulfill any of the conditions specified in article (12) above; 
or  
b. If the registration will negatively affect the integrity of the tax system.  
7. If the application is rejected, the FTA shall notify the applicant of the same within (5) 
five Business Days from the date of the FTA ’s rejection of the application.  
8. The registration in the Register shall be for (3) three years from the date of registration 
for a natural Person, and for one year from the date of registration for a legal Pe rson. 
The Tax Agent may submit an application to the FTA  to renew their registration in the 
Register in no later than twenty (20) Business Days before the expiry of their 
registration and after the prescribed fees are paid within the time limit specified by 
the FTA .  
9. Any renewal application submitted after the expiration of the time limit specified in 
Clause (8) above shall be treated as a new application and shall meet the conditions 
specified in article (12) above.  
10. If the Tax Agent fails to submit a regi stration renewal application before the expiry of 
the time limits referred to in Clause (8) above, they shall be deregistered and 
disengaged from all Persons they represent before the FTA, as of the expiry date of 
their registration in the Register.  
11. The Tax Agent shall notify the FTA if they cease to practice as a Tax Agent, pursuant 
to Clause (2) of article (13) of the Decree -Law, as per the form and mechanism 
determined by the FTA .  
12. The FTA may remove the Tax Agent from the Register, upon their request;  
13. The FTA shall remove the Tax Agent from the Register in any of the following cases:  
a. If The FTA finds that they are unable to carry out their functions or duties, or that 
they no long er fulfil the conditions set out in article (12) above;  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  14 
 b. If the FTA has serious reasons that the continuous registration of a Person as a Tax 
Agent in the Register would negatively affect the integrity of the tax system in the 
State;  
c. If they commit any se rious violation of the provisions of the Decree -Law or the 
Tax Law, or is involved in the Tax Evasion; or  
d. If the FTA becomes aware that they are a current member of the Committee.  
14. The FTA shall notify the Tax Agent and their principals of the deregistration 
decision within (5) five Business Days from the date of issuance, and the Tax Agent 
shall be notified of the grounds based on which such decision was issued.  
15. Clause (14) above shall entail disengagement of the Tax Agent from all Person 
they represent before the FTA, five (5) business days following the date of 
Notification of the FTA ’s decision.

Article (14)  
Obligations and Rights of the Tax Agent  
1. When exercising their functions, the Tax Agent shall:  
a. Assist the Person they represent before the FTA with regard to its Tax 
obligations pursuant to the agreement concluded between them;  
b. Keep any information obtained by the same in the course of performi ng their 
functions as a Tax Agent confidential, without prejudice to any obligation to 
disclose such information under law;  
c. Continue fulfilling the requirements of their professional development 
program, as determined by the FTA ;  
d. Refrain from participati ng in any action or plan that could lead to violating any 
law by any Person, or that could negatively affect the integrity and safety of the 
tax system; and  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  15 
 e. Maintain information, documents, records and data related to any Person they 
represent.  
2. The Tax A gent may, while exercising their functions, rely on the information 
obtained from the Person they represent, unless they have reasons to believe that 
such information is incorrect.

Article (15)  
Tax Auditing  
1. Before making a decision to conduct a Tax Aud it, the FTA shall take into account 
the following:  
a. The Tax Audit must be necessary to protect the impartiality and integrity of the 
tax system;  
b. The responsibility of the Person or any associated Person for compliance with 
the Decree -Law or the Tax Law;  
c. Tax revenues expected to be collected; and  
d. Compliance burdens and administrative burdens on both the FTA and the 
associated Person, pertaining to conducting the Tax Audit.  
2. The FTA may apply a Tax Audit to a Person that had been audited, taking into 
accou nt the following:  
a. Results of the previous Tax Audit; and  
b. Any new information or data that would change the FTA’s situation.  
3. FTA’s decision to conduct the Tax Audit shall be subject to the discretionary power 
of the FTA , and no Person may object to or challenge such decision.  
 
  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  16

Article (16)  
Notification of the Tax Audit  
1. The FTA shall notify the Person of the Tax Audit, at least (10) Business Days before 
conducting the Tax Audit. The notice served by the FTA  must make a reference to 
the potential consequences that could result from obstructing a tax auditor from 
practicing his  duties.  
2. For the purpose of applying Clause (4) of article (16) of the Decree -Law, the FTA 
shall notify the Person in writing of the Tax Audit commencement to:   
a. A tenant occupying the Headquarters if he is present when the Tax Audit starts; 
or  
b. A Person who acts as a  responsible officer at the Headquarters in the absence 
of the Tenant who occupies the Headquarters.  
3. If the FTA is convinced that the Notification of the Person of the Tax Audit by the 
means referred to in this Article is useless, it may notify the Person by posting the 
notice at a prominent place at the Headquarters where the Tax Audit will be 
conducted.

Article (17)  
Tax Audit Pr ocedures  
1. For the purpose of conducting the Tax Audit, the FTA may inspect/audit:  
a. The Headquarters and documents and Assets therein;  
b. Electronically -stored data and records; and  
c. Accounting systems used by the Taxable Person.  
2. For the purpose of applying Clause (1) above, a tenant occupying the 
Headquarters or any Person that FTA deems controlling the same, in the absence 
of the Tenant occupying the Headquarters, shall provide the FTA with all facilities 
necessary for exercising  its powers effectively.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  17 
 3. An employee of the FTA  may accompany the Tax Auditor to the Headquarters 
should the Tax Auditor deems such action necessary to enable him to exercise his 
powers effectively.  
4. The FTA shall notify the Person to provide any informat ion or show any 
documents related to them or to any other Person should such documents or 
information, at the desecration of the FTA , are necessary.  
5. If the Person is notified to provide information or submit documents under Clause 
(4) above, they shall pr ovide the same within the time limit and based on the form, 
means and place set out in the Notification.  
6. A tax auditor who practices auditing under an authorization issued by the Public 
Prosecution shall show the approval issued by the FTA  and the authorization 
issued by the Public Prosecution, and shall prove his identity where required.

Article (18)  
Seizure and Retention of Documents and Assets  
1. Upon exercising his functions, the Tax Auditor may:  
a. Take a copy of the documents;  
b. Label the original documents and Assets to refer that they are under going  
inspection;  
c. Reserve documents and Assets;  
d. Obtain information related to the Headquarters, Assets, documents and 
accounting systems that have been audited and registered.  
2. The Tax Auditor may impound any Assets or documents for periods determined 
by him, in order to complete the Tax Audit.  
3. If a document or asset is seized, pursuant to Paragraph (c) of Clause (1) above, the 
FTA shall submit a report containing items seized within (10) ten B usiness Days Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  18 
 from the seizure date, or within any other period determined by the FTA  for any of 
the following Persons:  
a. Owner of the document or Asset;  
b. Tenant occupying the Headquarters in which the document or Asset has been 
seized; or  
c. Person where the document or asset was in his possession or under his control 
immediately before being seized.   
4. The report referred to in Clause (3) above shall include the following:  
a. Purpose of the seizure on the document or Asset;  
b. Nature and description of the documen t or Asset;  
c. Place where the document or Asset is stored and the storage conditions; and  
d. Expected period of seizure by the FTA .  
5. The FTA may transfer, keep and store any documents or Assets that have been 
seized under Clauses (1) and (2) above for the period required to complete the Tax 
Audit, in accordance with the following conditions:  
a. The documents or assets that have been seized or  retained shall be returned to 
the Person to whom the report was submitted, pursuant to Clause (3) above in 
the best practicable condition.  
b. The FTA may dispose of Assets which are perishable by nature, in accordance 
with the FTA’s internal procedures.  
6. The FTA shall notify the Asset’s owner or any Person specified in Paragraph (b) or 
(c) of Clause (3) above, if it is not possible to notify the owner, of its desire to 
dispose of the Asset, in whole or in part, and shall give him an opportunity to 
entirely o r partially retrieve it before (10) ten Business Days from disposing of the 
Asset, pursuant to Paragraph (b) of Clause (5) above.  
7. The FTA shall assume no liability for any damage arising from the disposition of 
Assets, pursuant to Paragraph (b) of Clause (5) above.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  19 
 8. If the Person whose asset or document is seized submits an application to access 
thereto, the FTA may:  
a. Allow him to access to such document or asset under its supervision, 
photocopy or scan the document or photo the original and present the 
photograph or scanned copy to the relevant Person; or  
b. Reject the application if it deems that it would compromise:  
1. The Tax Audit;  
2. A Tax Audit related to another Person;  
3. Any investigation related to any of the documents or assets required to be 
accessed; or  
4. Any criminal proceedings related to the document or asset required to be 
accessed.  
9. Where the FTA needs to keep records and books for a longer period, exceeding the 
period set out in Clause (3) or article (3) above, it may seize and retain the same 
for a period specified by it.

Article (19)  
Result of Tax Audit  
1. A Person that is subject to the Tax Audit shall be notified of the Tax Audit result, 
within (10) Business Days of its completion.  
2. A Person that is subject to the Tax Audit may access to or obtain the documents, 
data and information based on which the FTA has assessed the Due Tax contained 
in the results of the Tax Audit, based on an application to be submitted as per the 
form specifi ed by the FTA  within (20) twenty Business Days from the date of 
Notification of the Tax Audit results.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  20 
 3. Subject to Clause (4) above, the FTA may provide the Person with the documents, 
data and information required pursuant to Clause (2) above, within (10) ten 
Business Days from receiving the application, as follows:  
a. A hard or soft copy of the required documents, data or information.  
b. An original copy of the required documents, data or information if such 
documents, data or information belong to the Person that is subject to the Tax 
Audit that submitted the application.  
4. The FTA is not bound to provide the Person with the following:  
a. Documents, data or information that could reveal any internal 
correspondence or decisions taken by the FTA ;  
b. Any confidential documents, data or information belonging to another Person; 
and  
c. Any documents, data or information that may be in the possession of the 
Person that is subject to the Tax Audit that has submitted the application. In 
this case, the FTA may provide the Perso n that is subject to the Tax Audit with 
adequate information that allows them to identify the required documents, 
data and information.

Article (20)  
Tax Assessment  
1. The Tax Assessment shall include adequate information to determine the value of 
the Due Tax, Refundable Tax or any other matters determined by the Tax Law. It 
shall include at least the following information of the relevant Person:  
a. Name and address;  
b. Tax Registration Number, if any;  
c. Tax Assessment reference number;  
d. Type of Tax under assessm ent;  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  21 
 e. Tax summary, including details of the declared Tax and adjustments made;  
f. Grounds on which the Tax Assessment is based;  
g. Net amount of the Tax payable to the FTA  or which will be refunded by it; and  
h. Due date for paying the Due Tax and the payment me thod.  
2. When a tax amount due to the FTA  is assessed and the Person is so notified, it shall 
serve as a debt payable to the FTA , and may be collected on such grounds.

Article (21)  
Assessment of Administrative Fines   
1. The assessment of administrative fines shall include at least the following 
information:  
a. Name and address of the Person;  
b. Tax Registration Number of the Taxable Person, if any;  
c. Violation requiring the assessment of administrative fines; and   
d. Summary of the administrative fines, including the following:  
(1) Amount of the imposed administrative fine;  
(2) Tax amount of the imposed administrative fine, if any;  
e. Total administrative fines payable to the FTA .  
2. When the amount of administrative fines is assessed and the person is notified 
thereof, it shall serve as a debt payable to the FTA  from the date of Notification, 
and can be collected on that basis.

Article (22)  
Procedures and Measures  
1. The FTA may sell seized and abandoned goods that are damageable, reducibl e or 
leakable, or that are in a condition that would compromise the safety of other Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  22 
 goods or the facilities existing therein, pursuant to the procedures contained in this 
Article.  
2. The FTA shall:  
a. Draw up a report to record seized goods and reasons for sei zure;  
b. Provide a copy of the report to the owner, and if it is not possible to notify the 
owner, any Person specified in Paragraph (b) or (c) of Clause (3) of article (18) 
above shall be notified;  
c. Notify the goods owner, and if it is not possible to notify  the owner, notify any 
Person specified in Paragraphs (b) or (c) of Clause (3) of article (18) above of 
the decision of selling goods, reasons therefor and the date scheduled for the 
sale.  
3. The sale under this Article shall be made in a public auction acco rding to the 
procedures set by the FTA .  
4. The FTA may destroy or dispose of the seized goods after notifying the owner in 
the following cases:  
a. Where it is not possible to sell the goods pursuant to this Article; or  
b. Where the seized goods are perishable by nature to the extent that they may 
lose their value, as per the internal procedures of the FTA .  
5. The owner of seized goods may request to reco ver the same after paying the full 
tax, administrative fines payable and any other expenses related to such goods; 
provided that such goods are saleable and tradeable in the State, as per the 
following conditions:  
a. He shall notify the FTA within (5) five B usiness Days from the date of being 
notified of the seizure;  
b. He shall submit to the FTA  evidence proving that:   
1. He owns the seized goods; and  
2. He has paid the full Tax, administrative fines and expenses related to such 
seized goods.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  23 
 6. The FTA shall determ ine the procedures and controls for storing and transporting 
the seized goods are damageable, reducible or leakable, or in condition that would 
compromise the safety of other goods and facilities existing therein.

Article (23)  
Conciliation on Tax Evasio n Offences  
1. Before initiating a criminal action, the FTA may accept conciliation in respect of the 
Tax Evasion offences and deliberate abstention from paying administrative fines 
in return for paying the full Tax payable and administrative fines.  
2. Before in itiating a criminal action, the FTA may accept conciliation  in respect of the 
offences set forth in Clause (4) of article (25) of the Decree -Law after paying an 
amount of (AED 50,000) fifty thousand dirhams. If any of such offences causes a 
Tax Evasion or leads to the facilitation or concealment thereof, the conciliation  
shall be ma de by paying the consideration shown in Clause (1) above.  
3. After the criminal action is initiated and during the phase of investigation and trial, 
before a judgement of conviction is rendered and after consulting the FTA, the 
Public Prosecution may accept conciliation on the tax offences in return for the 
payment of the following amounts:  
a. The full Due Tax and administrative fines, plus an amount equivalent to (50%) 
of the tax amount evaded , pertaining to the offences set forth in Clause (2) of 
article (25)  of the Decree -Law;  
b. The full Due Tax and administrative fines, plus an amount equivalent to (50%) 
of the tax amount evaded , if any, pertaining to the offence of deliberate 
abstention from paying the administrative fines set forth in Clause (3) of Article 
(25) of the Decree -Law; or  
c. An amount of (AED 100,000) one hundred thousand dirhams for offences set 
forth in Clause (4) of article (25) of the Decree -Law. If any of such offences Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  24 
 causes a Tax Evasion or leads to the facilitation or concealment thereof, the  
conciliation  shall be made by paying the consideration shown in Clause (a) 
above.  
4. After a judgement of conviction is rendered and after consulting the FTA, the 
Public Prosecution may reconcile Tax offences in return for the payment of the 
following amoun ts:  
a. The full Due Tax and administrative fines, plus an amount equivalent to (75%) 
seventy five percent of the tax amount evaded , pertaining to the offences set 
forth in Clause (2) of article (25) of the Decree -Law;  
b. The full Due Tax and administrative fines, plus an amount equivalent to (75%) 
seventy five percent of the tax amount evaded , if any, pertaining to the offence of 
deliberate abstention from paying the administrative fines set forth in Clause (3) 
of article (25) of the Decree -Law; or  
c. An amount of (AED 200,000) two hundred thousand dirhams for offences set 
forth in Clause (4) of article (25) of the Decree -Law. If any of such offences causes 
a Tax Evasion or leads to the facilitation or concealment thereof, th e conciliation  
shall be made by paying the consideration shown in Clause (a) above.  
5. If more than one action of the actions set out in Clause (4) of article (25) of the 
Decree -Law is committed for one purpose, and such actions are indivisibly related 
to ea ch other, the conciliation  shall be made for all such actions collectively, in 
return for payment of the amount set out in Paragraph (c) of Clause (3), or 
Paragraph (c) of Clause (4) above, as the case may be.  
 
  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  25

Article (24)  
Conciliation  Conditions, Controls and Procedures  
1. The conciliation  application shall be submitted by the Person to the FTA  on the 
form prepared for such purpose, before a criminal action is initiated. The form shall 
include an undertaking to pay the full amounts owed by them as a consideration 
for the conciliation .  
2. FTA shall decide either to accept or reject the conciliation  application. If FTA 
decides to accept the application, a report on the same shall be drawn up to record 
the conciliation  and the consideration th ereof and be signed by both parties, and 
a copy thereof shall be delivered to the Person after paying the conciliation  
consideration.  
3. The conciliation  application shall be submitted by the accused or convict, as the 
case may be, at any stage of the crimin al action to the competent federal Public 
Prosecution.  
4. Before initiating the procedures of conciliation  in Tax offences, the Public 
Prosecution shall seek the opinion of the FTA . If no reply is received from the FTA 
within (20) twenty business days, such action serves as implicit consent of the 
conciliation .  
5. The Public Prosecution shall draw up a report of the conciliation  after the payment 
of the full Tax, payable administrative fines and the additional consideration for 
the conciliation , and shall be si gned by both the competent Public Prosecution 
member and the accused or convict, and shall be approved by the Federal 
Attorney -General. The report must include the following:  
a. Data of the accused or convict;  
b. A description of charges attributed to the accu sed or convict, date and place of 
their occurrence and articles of law applicable thereto;  
c. Amount of Tax and administrative fines payable; and  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  26 
 d. Stating the percentage and amount of the additional consideration for 
conciliation .  
The report shall be accomp anied by a proof of payment of the aforementioned 
amounts. Where the administrative fines are paid in installments or are exempted, 
pursuant to article (50) of the Decree -Law, or the payment of the additional 
consideration of conciliation  is postponed or p aid in installments, pursuant to 
Clause (9) above, a plan of payment of deferred or installed amounts, as the case 
may be, shall be attached to the report. The FTA and the Competent Court shall be 
notified of the approved conciliation  report, as the case m ay be.  
6. The Public Prosecution shall order to stay the execution of the adjudicated penalty 
if the conciliation  is made during the execution thereof, even if the judgement 
becomes final.  
7. The completion of conciliation  in accordance with the above shall terminate the 
criminal action for the incident, subject of conciliation , and shall eliminate the 
impacts arising therefrom.  
8. Multiple accused or convicts in the criminal case shall not prevent the Public 
Prosecution from proceeding with the conciliation  proceedings with one or some 
of them, and the effect of conciliation  shall extend to all accused persons or 
convicts in the sam e incident.  
9. The Public Prosecution may, at the request of the accused person or convict, order 
to postpone the payment of the conciliation  consideration and to be paid in 
installments according to the following conditions:  
a. The postponement or installment must not include the tax payable or 
administrative fines;  
b. The period of postponement or installment must not exceed two years; and  
c. The accused person or convict must provide adequate safeguards.  
The Public Prosecution may revoke the order of postponemen t or installment if it 
finds a reason for doing so.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  27 
 10. The conciliation  shall be null and void and all effects thereof shall terminate where 
the accused person or convict fails to comply with Clause (9) above or violates the 
payment plan referred to in Claus e (5) above.  
11. In all cases, the payment of the conciliation  consideration, i.e. the Payable Tax and 
administrative fines, shall be made in favour of the FTA .

Article (25)  
Extension of Time Limits  
1. The FTA may extend the time limit for deciding on an app lication for reviewing the 
Tax Assessment and an application for reconsideration that fulfils the conditions 
of formalities for (20) twenty Business Days if the extension is necessary to decide 
on the application.  
2. The Committee may extend a time limit for  deciding on a Tax objection, which 
fulfils the formal requirements, for (60) sixty Business Days if the extension is 
necessary to decide on the objection.   
3. The Committee may, at the request of stakeholders, extend the time limit for 
submitting an applica tion for reviewing the Tax Assessment or an application for 
reconsideration in cases assessed by the FTA .  
4. The Committee may, at the request of stakeholders, extend the time limit for 
accepting the submission of Tax objection if it found a reason beyond re asonable 
control, an accident, unforeseen circumstances or force majeure precluded the 
submission of the Tax objection within the prescribed time limits.  
5. For the purposes of Clauses (3) and (4) above, the application shall be submitted 
together with the e xtension justifications and reasons for the subject matter of 
review, reconsideration or objection.  
 
  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  28

Article (26)  
Tax Refund Procedures  
1. A Taxpayer that is entitled to refund the Tax under the Tax Law or the Decree -Law 
may submit a refund application, as per the form and mechanism determined by 
the FTA .  
2. The FTA shall decide on the refund application under Clause (1) above, and shall 
notify the Taxpayer of its decision within (20) twenty Business Days from the date 
of submitting the refund application, or within any other time limit that may be 
necessary to de cide on the refund application; provided that the Taxpayer is so 
notified.  
3. If the FTA approves the refund application, it shall, within (5) five Business Days 
from the date of notification, pursuant to Clause (2) above, take actions to 
reimburse the amoun t to the Taxpayer, as per the mechanism determined by the 
FTA .  
4. FTA may postpone the Tax refund until any due Tax Returns are submitted to the 
FTA  and have not been submitted when the Tax refund application is received. In 
this case, the excess amount shal l be refundable after submitting such Tax Returns, 
taking into account the conditions set forth in the Decree -Law and the Tax Law.

Article (27)  
Payment of Tax and Administrative Fines in Bankruptcy Cases  
1. If a business or part thereof enters into bankrup tcy proceedings and a bankruptcy 
trustee  is appointed thereto, the latter shall be treated as a representative of the 
Person with respect to its business or part thereof up to the expiration of the term 
of their appointment.  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  29 
 2. The bankruptcy trustee  shall n otify FTA of their appointment, within (20) twenty 
Business Days from the date of their appointment pursuant to the provisions of 
article (8) above.  
3. The FTA shall inform the appointed bankruptcy trustee  of the Due Tax amount or 
of its desire to conduct a Tax Audit over specific Tax Period(s), within (20) twenty 
Business Days from the date of notifying the FTA of the appointment of the 
bankruptcy trustee , pursuant to Clause (2) above.  
4. The bankruptcy trustee  shall pay the Payable Tax to the FTA  according to the 
mechanism of paying the Payable Tax, pursuant to the Decree -Law and the Tax 
Law.

Article (28)  
Confidentiality and Disclosure of Information  
1. Employees of the FTA  and persons assigned by the FTA  to implement the 
provisions of the Decree -Law or the Tax Law shall, during and after their 
employment and assignment, not disclose the information that was in their 
possession or that they had accessed thereto during their employment or for 
carrying out t heir assigned functions, except in the following cases:  
a. The disclosure must be based on a decision by the judicial authority for the 
purposes of a civil or criminal action before the competent court on a matter 
falling within the FTA’s scope of work;  
b. The  disclosure must be made be for a competent government authority after 
being determined by a decision of the Board of Directors, i.e. concluding a 
memorandum providing for the disclosure, determining the permissible use of 
the disclosed information and the  procedures made for subsequent monitor, 
security and permission and accuracy of information, including access to this 
information by persons.   Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  30 
 c. The disclosure must be in pursuance of international convention or treaties.   
d. The disclosure must be related to the Person, their legal representative,  or their 
Tax Agent, at the request of one of them, on the Person’s file held by the FTA ; 
and  
e. The disclosure must be to one of the FTA ’s employees in charge and  shall be 
made at a place in accordance with the conditi ons of confidentiality, where by 
the FTA  expects that such Person will perform his duties and functions.  
2. For the purposes of implementing the provisions of Clause (1) above, the “FTA 
employees” shall mean:  
a. The Chairman and Board Members;  
b. The Director -General; and  
c. Any other employee of the FTA .  
3. For the purposes of implementing the provisions of this Article, the Board of 
Directors shall specify the following:  
a. The FTA employees and Persons assigned by it w hose jobs allow them to 
disclose information and nature or category of such information permitted to 
be disclosed; and  
b. Date on which the disclosure is permitted.

Article (29)  
Requesting Information and Documents  
The FTA may request accounting records, commercial books and any other data and 
information from any Person, in order to carry out its functions and powers under the 
Decree -Law, the Tax Law and any executive resolution thereof.  
 
  Cabinet Resolution No. (74) of 2023, on the Executive Regulations of Federal Decree -Law No. (28) of 2022  
on Tax Procedures  31

Article (30)  
Repeals  
1. Cabinet Resolution No. (36) of 2017, on the Executive Regulations of Federal Law 
No. (7) of 2017, on Tax Procedures, as amended, shall hereby be repealed.  
2. Any provision contrary to or in conflict with the present Resolution shall hereby 
be repealed.  
3. The resolutions issued by the FTA  and the procedures applied by it, pursuant to 
Cabinet Resolution No. (36) of 2017, on the Executive Regulations of Federal Law 
No. (7) of 2017, on Tax Procedures, as amended, shall remain in force, in so far as 
they do not con tradict the provisions of the present Resolution, until the substitute 
resolutions and procedures are issued, pursuant to the provisions of this 
Resolution.

Article (31)  
Publication and Entry into Force  
1. This Resolution shall be published in the Officia l Gazette, and shall enter into force 
as of 1st August 2023.  
2. Notwithstanding Clause (1) above, Clause (2) of article (12) above shall enter into 
force as of 1st December 2023.  
 
 
Mohammed bin Rashid Al Maktoum  
Prime Minister  
 
Issued by Us:  
Dated: 22nd Dhu al -Hijja 1444 AH,  
Corresponding to: 10th July 2023 AD