Federal Decree by Law No. (28) of 2022 Concerning Tax Procedures (tax law)

Article (1) 
Definitions  
For the purpose of applying the provisions of this Decree -Law, the following words and 
expressions shall have the meanings assigned thereto respectively, unless the context 
requires otherwise:  
State  : The United Arab Emirates.  
Minister  : The Minister of Finance.  
FTA  : The Federal Tax Authority  
Director -General  : The Director General of FTA.  
Business Day  : Any weekday, except for weekends and public holidays of 
the Federal Government.  
Committee  : The Tax Dispute Settlement Committee.  
Competent Court  : The federal court within the jurisdiction of which the 
headquarters of FTA or any of its branches is located.  
Tax  
 : Any federal tax levied by virtue of the Tax Law where the 
management, collection and implementation thereof is 
entrusted to the FTA.  
Tax Law  : Any federal law whereby the Tax is levied.  
Tax Domicile 
Certificate  : A certificate issued by the FTA confirming the Tax domicile 
of a person in the State, pursuant to the provisions of Article 
(53) hereof.  
Tax Resident  : A person residing in the State, pursuant to article (53) hereof.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  3 
 Person  : A natural or legal person.  
Business  : Any activities carried out regularly, continuously and 
independently by any Person anywhere, such as industrial, 
commercial, agricultural, professional, craft, service or 
drilling activities, any activity related to the use of tangible or 
intangible property, or any other activity determined by the 
Tax Law.  
Taxable Person  : Any Person registered or  required to be registered for the 
purpose of the provisions of the Tax Law.  
Taxpayer  : Any person required to pay the Tax in the State under the 
Tax Law, whether a Taxable Person or end consumer.  
Tax Return  : The information and data specified for tax ation purposes 
and provided by the Taxable Person, according to the form 
and mechanism designated by FTA, including the relevant 
annexes and schedules  
Tax Period  : The period of time specified in the Tax Law for which the Tax due is required to be calculated.  
Tax Registration  : It is a procedure whereby a Person registers its name with 
the FTA or the latter registers the same with it, as the case 
may be, for Tax purposes.  
Tax Registration 
Number  : It is a unique number issued by FTA for each Person for Tax 
purposes.  
 
Registered 
Person  : The Taxable Person having a Tax Registration Number.  
Legal 
Representative  : A guardian, trustee or curator with regard to incapacitated Persons or Persons with diminished capacity, or the court -appointed bankruptcy tru stee with regard to a 
company undergoing bankruptcy, or any Person legally appointed to represent another Person.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  4 
 Due Tax  : A Tax that is calculated and levied under the provisions of 
the Tax Law.  
Payable Tax  : A Tax payable to FTA  
Administrative Fines  : Sums imposed on the Person by FTA due to the violation of the provisions of this Decree -Law, the Tax Law or the 
cabinet resolutions issued in implementation thereof.  
Refundable Tax  : Amounts refundable by FTA to the Taxpayer, in whole or in part, purs uant to the Tax Law and this Decree -Law.  
Tax Assessment  : A decision made by FTA under article (23) hereof.  
Assessment of 
Administrative 
Fines  : A decision issued by FTA on the Administrative Fines.  
Notification  : Notifying the Person of decisions iss ued by the FTA, as per 
the means set forth in this Decree -Law and the Executive 
Regulations hereof.  
Voluntary Declaration  : 
It is a form designated by FTA whereby the Taxpayer notifies FTA of any error or omission in the Tax Return, Tax 
Assessment or tax  recovery application, pursuant to the 
provisions of article (10) hereof.  
Register  : The Tax Agent Register.  
Tax Agent  : Any Person registered with FTA authorized by another 
Person to represent it before FTA, help it to perform its tax 
obligations and e xercise its relevant Tax rights.  
Tax Audit  : It is a procedure carried out by FTA for auditing commercial records or any information, data or commodities related to a 
Person to verify the fulfillment of their obligations under this 
Decree- Law or the Tax L aw. 
Tax Auditor  
 : Any FTA employee appointed to carry out the Tax Audit.  
Tax Evasion  : The Person's use of illegal means that result in reduced  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  5 
 amount of the Due Tax, non -payment of Tax or recovery of a 
Tax which the Taxpayer has no right to recover ac cording to 
this Decree- Law or the Tax Law.  
Executive 
Regulations  : The Executive Regulations of this Decree -Law.

Article (2) 
Objectives of this Decree- Law  
This Decree -Law is intended to:  
1. Regulate rights and obligations of the FTA, Taxpayers and any other Person dealing with 
the FTA, in compliance with the provisions of this Decree -Law or the Tax Law.  
2. Regulate common procedures and rules applicable to all tax laws in the State.

Article (3) 
Scope of Application  
The provisions of this Decree -Law shall apply to the procedures related to the management, 
collection and implementation of tax laws and Administrative Fines levied by FTA for 
violating the provisions of this Decree -Law or the T ax Law.  
  
Part Two  
Tax Obligations  
Chapter One  
Keeping Accounting Records and Commercial Books

Article (4) 
Record- Keeping  
Any Person that carries out any business or is subject to a Tax obligation under the Tax Law 
shall keep records for their accounting activities and commercial books, as well as any 
tax-related information as determined by the Tax Law, in conformity with th e controls laid  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  6 
 down by the Executive Regulations.

Article (5) 
Language  
1. Every Person shall submit the Tax Return as well as data, information, records and 
documents related to the Tax they are obligated or required to submit to the FTA in 
Arabic.  
2. Notwithstanding the provisions of Clause (1) above, FTA may accept the Tax Return and 
the information, data, records and documents related to the Tax in any other language; 
provided that the Person provides FTA with a translated copy of any of the same into 
Arabic if required by the FTA, as stipulated by the Executive Regulations.  
3. A Person that submits any translated copy of the data, information, records and any 
other documents related to any tax to FTA shall be liable for the accuracy and validity  of 
such translated copies, and shall bear all relevant costs. The FTA may rely on the 
translation submitted thereto.  
  
Chapter Two  
Tax Registration

Article (6) 
Tax Registration, Deregistration and Amendment to Data  
1. The Taxable Person may submit the registration application to the FTA pursuant to the 
provisions set forth in the Tax Law.  
2. The Registered Person shall:  
a. Include its Tax Registration Number in all communications and transactions with 
FTA and third parties according to the provisions of the Tax Law.  
b. Notify FTA according to the form and mechanism designated by FTA of the 
occurrence of any case that may require amendment to the information related to its 
Tax Register kept at FTA, within twenty (20) business days from the occurrence date 
of such case.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  7 
 c. Submit a deregistration application in accordance with the relevant provisions in the 
Tax Law.  
3. The Executive Regulations shall determine the Tax Registration and deregistration procedures as well as the amendment to its data.  
4. Government bodies in charge of granting business licenses shall notify FTA upon 
granting any license, no later than twen ty (20) business days from the issuance date of 
the license, as stipulated in the Executive Regulations.

Article (7) 
Legal Representative 
The Legal Representative shall:  
1. Notify FTA of his appointment, within twenty (20) Business Days from the appoin tment 
date, according to the procedures defined by the Executive Regulations;  
2. Submit Tax Returns to FTA on behalf of the Taxable Person; and  
3. Comply with any requirements under this Decree -Law and the Tax Law, as the case may 
be. 
 
 
 
  
Chapter Three  
Tax Return and Payable Tax

Article (8) 
Tax Return Preparation and Submission  
1. Every Taxable Person shall:  
a. Prepare and submit the Tax Return to FTA pursuant to the provisions of this 
Decree- Law and the Tax Law; and  
b. Pay any Payable Tax within the time limit set forth in this Decree -Law and the Tax 
Law.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  8 
 2. Any incomplete Tax Return delivered to FTA shall not be admitted if the same fails to 
contain the basic data defined by the Tax Law.  
3. Any Taxable Person shall be responsible for the authenticity of information and data contained in the Tax Return and any communications with FTA.  
4. Any Taxpayer shall pay the Payable Tax and the Administrative Fines within the time 
limit defined in this Decree -Law and the Tax L aw.

Article (9) 
Determination of the Payable Tax 
1. The Taxable Person shall, upon the payment of any amount to FTA, determine the type 
of Tax and the Tax Period related to such amount, and FTA shall allocate the paid 
amount accordingly.  
2. When the Taxable Person pays any amount without determining the type of Tax or Tax Period, FTA may allocate the amount or a part thereof for the payment of any Tax or 
amounts owed by the Taxable Person, as defined by the Executive Regulations.  
3. If the Taxable Person pays an amount greater than the Payable Tax amount or has a credit balance with FTA, FTA may allocate the amount or the balance for the payment of any Tax or amounts owed by the Taxable Person, as defined by the Executive 
Regulations.  
4. If the Taxable Person pays an amount less than the Payable Tax amount, the provisions 
set out in Chapter Fo ur of Part Three  and Chapter Two  of Part Fi ve hereof shall apply.  
  
Chapter Four  
Voluntary Declaration

Article (10) 
1. If the Taxable  Person finds out that the Tax Return submitted to FTA or the Tax 
Assessment issued by FTA is incorrect in a way which causes the Payable Tax according 
to the Tax Law be calculated in an amount less than the correct amount, they shall 
submit a Voluntary De claration.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  9 
 2. If the Taxpayer finds out that the tax recove ry application submitted to FTA is incorrect, 
in a way which causes the recovery amount due to them under the Tax Law be 
calculated at in an amount higher than the correct amount, they shall submit a Voluntary 
Declaration.  
3. If the Taxable Person finds out that the Tax Return submitted to FTA or the Tax 
Assessment issued by FTA is incorrect, in a way which causes the Payable Tax according 
to the Tax Law be calculated in an amount higher than the correct amount, they may 
submit a Voluntary Declaration.  
4. If the Taxpayer finds out that the Tax recovery application submitted to FTA is incorrect, 
in a way which causes the recovery amount due to them under the Tax Law be 
calculated at an amount less than the correct amount, they may submit a Voluntary 
Decla ration.  
5. If the Taxpayer finds out an error or omission in the Tax Return submitted to FTA, without a difference in the Tax amount due, they shall correct such return by submitting a Voluntary Declaration.  
6. The Executive Regulations shall define th e detailed provisions related to the Voluntary 
Declaration to the FTA, and the mechanism of applying the Administrative Fines levied 
before the Voluntary Declaration.  
  
Part Three  
Tax Procedures  
Chapter One  
Notification

Article (11) 
Methods of Notification  
1. FTA shall notify the Person of any decisions or procedures through their address registered with the FTA.  
2. The Person shall be deemed to have been notified of any decision and has received any communications if the FTA has sent Notifications and communications according to  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  10 
 Clause (1) above.  
3. The Executive Regulations shall define the means of Notification and communications.  
  
 
 
 
Chapter Two  
Tax Agents

Article (12) 
Tax Agent Registration  
1. FTA shall create a Tax Agent Register.  
2. Any Person may operate as a Tax Agent in the State only after fulfilling the registration 
conditions, being registered in the Register and obtaining the license from the competent local authority.

Article (13) 
Requirements for Registration in the Register  
1. The Executive Regulations shall determine the conditions, controls and procedures for 
registration, suspension of registration and deregistration of the Tax Agent in the 
Register, as well as rights and obligations of the Tax Agent.  
2. The Tax Agen t shall notify FTA if they cease to operate as a Tax Agent, pursuant to the 
controls and procedures set out in the Executive Regulations.

Article (14) 
Appointment of Tax Agent  
1. The Person may appoint a Tax Agent to act on its behalf and in its name in respect of its obligations on Tax affairs under this Decree -Law or the Tax Law, without prejudice to 
the liability of such Person under this Decree -Law or the Tax Law.  
2. Subject to Clause (2) of article (15) above, FTA may not deal with the Tax Agent in  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  11 
 respect of any Person if the latter notifies FTA of expiration of the agency or dismissal of 
the Tax Agent, as described in the mechanism set by FTA.

Article (15) 
Records of the Person with the Tax Agent  
1. The Tax Agent shall retain the information, documents, records and data related to any Person represented or that had been represented by the Tax Agent, within the period 
and in such manner as described in the Executive Regulations.  
2. The Tax Agent shall, upon FTA request, provide the same with all information, 
documents, records and data in their possession required in respect of any Person 
represented or that had been represented by the Tax Agent.  
  
Chapter Three  
Tax Audi t

Article (16) 
FTA's Right to Conduct Tax Audit  
1. FTA may conduct a Tax Audit of any Person in order to verify the compliance with the 
provisions set forth in this Decree -Law and the Tax Law.  
2. FTA shall notify the Person of a Tax Audit at least (10) ten days prior to the Tax Audit.  
3. FTA may conduct the Tax Audit at FTA's headquarters, the business place of the Person 
subject to audit or elsewhere at which such Person carries out their busine ss, stores 
commodities or keeps records.  
4. Notwithstanding the provisions of Clause (2) above, a tax auditor may access, without prior notice, to anywhere at which the Person subject to audit carries out its business, 
stores commodities or keeps records, and may close down the same temporarily for conducting the audit for a period not exceeding (72) seventy two hours in any of the 
following cases:  
a. If FTA has serious reasons to believe that the Person subject to the Tax Audit is 
involved or implicate d in Tax evasion in respect of the obligations of such Person or  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  12 
 any other Person imposed by this Decree -Law or the Tax Law.  
b. If FTA has serious reasons to believe that failure to temporarily close down the place 
at which the tax audit is conducted may  impede the audit.  
c. If the Person that had been notified of the Tax audit under Clause (2) above attempts 
to prevent the Tax auditor's access to the place at which the Tax audit is to be 
conducted.  
5. In all the cases set forth in Clause (4) above, the Tax auditor shall obtain prior written 
consent of the Director -General or his representative and permission from the Public 
Prosecution if the place required to be accessed is a housing place.  
6. Premis es closed down under this Article shall be reopened after the lapse of the (72) 
seventy -two hours, unless FTA obtains permission from the Public Prosecution that 
permits the extension of the closure period for a similar period before the lapse of the 
menti oned seventy -two hours.  
7. The Executive Regulations shall determine the necessary procedures related to Tax audit.

Article (17) 
FTA's Right to Access to Original Records or Photocopies During Tax Audit  
A Tax auditor may, while conducting the Tax Audit , access to original records or photocopies 
thereof and take samples of goods, devices or other assets from the business place of the Person subject to the Tax Audit or those in its possession or seize the same, in accordance 
with the controls defined by t he Executive Regulations.

Article (18) 
Tax Audit Timing  
A Tax Audit shall be conducted during the normal business hours of FTA. If necessary, the 
audit may be conducted beyond such times under extraordinary circumstances by a 
decision of the Director -General or his representative.

Article (19)  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  13 
 New Information Appears After Tax Audit  
Without prejudice to the provisions of article (46) hereof, FTA may audit any matter that 
had already been audited if new information comes out that may affect the outcome  of the 
Tax audit; provided that such audit shall be subject to the Tax audit procedures in 
accordance with the provisions of this Decree -Law and the Executive Regulations thereof.

Article (20) 
Cooperation During Tax Audit  
Any Person subject to a Tax Aud it or their Tax Agent or legal representative shall be required 
to provide all facilities and possible assistance to the Tax auditor in order to enable him to 
perform his job.

Article (21) 
Rights of Persons Subject to Tax Audit  
A Person subject to a Tax audit shall have the right to:  
 
1. Request Tax auditors to show their professional ID cards;  
2. Obtain a copy of the Tax audit Notification;  
3. Attend the Tax audit conducted outside FTA; and  
4. Obtain copies of any original paper or digital documents that are seized or obtained by FTA upon the Tax audit, as defined by the Executive Regulations.

Article (22) 
Notification of Tax Audit Findings  
1. FTA shall notify the Person subject to Tax Audit  of the Tax Audit outcome within the 
time limit and according to the procedures determined by the Executive Regulations.  
2. The Person subject to Tax audit may access to and obtain the documents and 
information relied upon by FTA for assessment of the Due Tax according to the controls set by the Executive Regulations.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  14 
   
Chapter Four  
Tax Assessment and Assessment of Administrative Fines

Article (23) 
Tax Assessment  
1. FTA shall issue a Tax Assessment to determine the value of the Payable Tax, Refundable 
Tax or any other matters specified by the Tax Law or the Executive Regulations, and shall 
notify the Taxpayer of the same within (10) ten Business Days from the issuance  date 
thereof in any of the following cases:  
a. The Taxable Person fails to apply for the Tax Registration within the time limit 
prescribed in the Tax Law.  
b. Failure of the Registered Person to submit the Tax Return within the time limit 
prescribed by the Tax Law.  
c. The Registered Person's failure to pay the Tax indicated as a Payable Tax in the Tax Return submitted within the time limit prescribed in the Tax Law.  
d. The Taxable Person has submitted an incorrect Tax Return.  
e. The Registered Person's failure to calculate the Tax on behalf of another Person when he is obliged to do the same in accordance with the Tax Law.  
f. If the Payable Tax is incomplete as a result of Tax Evasion by the Person or due to Tax Evasion in which he was involved.  
g. Any other cases under the Tax Law.  
2. FTA may issue an estimated Tax Assessment of the Payable Tax and the Refundable Tax if it is not possible to determine the actual amount of the Payable Tax or the authenticity 
of the Tax Return. In this case, FTA shall:  
a. Amend the estimated Tax Assessment issued under this Article based on new 
information that may affect the subject of the  Tax Assessment.  
b. Notify the Person concerned of such amendments within (10) ten Business Days 
following the amendment date.  
3. The Executive Regulations shall specify the information or data to be included in the Tax Assessment.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  15

Article (24) 
Assessment of Administrative Fines  
1. FTA shall issue an assessment of Administrative Fines and inform the Person of same 
within (5) five Business Days in respect of any of the following violations:  
a. The Person that carries out business or is subject  to a Tax obligation under this 
Decree- Law or the Tax Law fails to keep the required records and other information 
specified both in this Decree -Law and the Tax Law.  
b. The Person that carries out business or is subject to a Tax obligation under this Decree -Law or the Tax Law fails to submit the data, records and documents related 
to the Tax in Arabic to FTA upon request.  
c. The Taxable Person fails to submit the Tax Registration application within the time 
limit specified in the Tax Law.  
d. Failure of the Registered Person to submit a deregistration application within the 
time limit specified in the Tax Law.  
e. Failure of the Registered Person to inform FTA of any situation that may require 
amendment to the information related to its tax re gister kept by FTA.  
f. The Legal Representative of the Taxable Person fails to report his appointment as a 
legal representative within the specified time limits. In such a case, fines shall be 
collected from the funds of the Legal Representative.  
1. The Legal Representative of the Taxable Person fails to submit the Tax Return within 
the specified time limits. In such a case, fines shall be collected from the funds of the 
legal representative.  
h. Failure of the Registered Person to submit the Tax Retur n within the time limit 
specified in the Tax Law.  
i. The Taxable Person fails to pay the Due Tax within the time limit specified in the Tax 
Law.  
j. The Registered Person has submitted an incorrect Tax Return.  
k. A Voluntary Declaration submitted by the Taxable Person or Taxpayer on errors in the Tax Return, Tax Assessment or the application for recovery of the Tax, in  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  16 
 accordance with clauses (1) and (2) of article (10) above.  
l. The Taxable Person or Taxpayer fails to make a Voluntary Declaration of errors in the 
Tax Return, Tax Assessment or tax recovery application, in accordance with Clauses 
(1) and (2) of article (10) of this Decree -Law before being notified that FTA 
conducted a Tax Audit on it.  
m. The Pers on that is subject to the Tax Audit or their Tax Agent or Legal Representative 
fails to provide facilities for the Tax auditor, in violation of the provisions of article (20) of this Decree -Law. In such a case, fines shall be collected from the funds of the 
Person or their legal representative or Tax Agent, as the case may be.  
n. The Registered Person fails to calculate the Tax for another Person when the 
registered Taxable Person is obligated to do the same in accordance with the Tax 
Law.  
o. Any other violation included in the Tax Law or under a resolution of the Cabinet.  
2. The Executive Regulations shall specify the information and data to be included in the assessment of Administrative Fines.  
3. The Cabinet shall issue a Resolution setting out the Administrative Fines for each of the violations mentioned in Clause (1) above, with regard to this Decree -Law, the Tax Law or 
any other violation specified under a Cabinet resolution.  
4. The amount of any Administrative Fine shall not exceed twice the Tax amount on which 
the Assessment of Administrative Fines has been issued.  
5. The imposition of any Administrative Fine under the provisions of this Decree -Law or 
any other law shall not relieve any Person from their liability to pay th e Due Tax, in 
accordance with the provisions of this Decree -law or the Tax Law.  
  
 
 
Chapter Five  
Penalties, Procedures and Measures

Article (25) 
Tax Crimes and Penalties   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  17 
 1. The penalties set forth herein shall not prejudice to any severer penalty stipulated in any 
other law.  
2. A prison sentence and/or a fine not less than the evaded Tax amount and not more than (3) three times the amount of evaded Tax shall be inflicted on  any Person committed the 
Tax Evasion by one of the following act:  
a. Deliberately refrains from paying any Payable Tax;  
b. Deliberately reduces the actual value of its business or revenues or does not include 
its associates business in order not to re ach the required registration limit, Tax rate or 
other Tax threshold, as specified in the Tax Law;  
c. Deliberately levies or collects amounts as a Tax without being registered;  
d. Deliberately reduces the Tax due or engages, in any manner, in the Tax E vasion;  
e. Deliberately performs or fails to perform any other act that would constitute a Tax 
Evasion under this Decree -Law or the Tax Law.  
3. A prison sentence and/or a fine not less than the amount of the Administrative Fine and 
not more than (3) three times the amount thereof shall be inflicted on any Person that 
abstains from paying the payable Administrative Fine, unless it is decided to be 
exempted.  
4. A prison sen tence and/or a fine not exceeding (AED 1,000,000) one million dirhams 
shall be inflicted on any Person committing any of the following acts:  
a. A Person that intentionally provides false information, data and documents to FTA;  
b. A Person who intention ally hides or destroys documents, data, information or other 
materials that are required to be kept and provided to FTA;  
c. A Person who has stolen, abused or caused damage to documents or other materials kept by FTA; and  
d. A Person who prevents or impedes employees of FTA from carrying out their duties.  
5. If any of the above acts takes place and cause Tax Evasion or its facilitation or concealment, the penalty set forth in Clause (2) above shall be applicable.  
6. Any Pe rson who is proven to have been involved directly in or caused one of the crimes 
set forth in this Decree -Law or the Tax Law shall be penalized by the penalty prescribed 
therefor in this Decree -Law, pursuant to the provisions of criminal involvement set fo rth  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  18 
 in Decree- Law No. (31) of 2021, referred to hereinabove.  
7. If multiple convicts are fined by one judgment in one crime, whether they are the 
perpetrators or accomplices, they shall be jointly liable to pay the same.  
8. Recidivism shall constitute an aggravating circumstance. For the purpose of this 
Decree- Law or the Tax Law, a recidivist is any Person who is convicted by a final 
judgment in one of the crimes set forth in this Article, whatsoever the penalty, then commits one of such crimes before t he lapse of (5) five years from the date on which the 
said final judgment is rendered.  
9. Without prejudice to the provisions of Clause (11) hereunder, any Person involved in a Tax Evasion crime shall be severally and jointly liable with the involved Per son for 
paying the Payable Tax and the Administrative Fines.  
10. When the Court renders a judgment on conviction, it shall order to publish the judgment 
or a summary thereof with the appropr iate means at the expense of the convict, at the 
request by FTA to the Public Prosecution.  
11. The judgment on any penalty under the provisions of this Decree -Law or any other law 
shall not exempt any Person from the liability for paying the Payable Tax  or the 
Administrative Fines.

Article (26) 
Procedures and Measures  
1. A criminal action may be instituted against the crimes set forth in this Decree -Law or the 
Tax Law only based on a written application from the Director -General.  
2. Without prejudice to the cases in which the Law requires the confiscation ruling, the 
Court may, when a judgment of conviction is rendered in respect of any crime set forth 
in this Decree -Law or the Tax Law, order that the detected items and property be 
confiscated, with out prejudice to bona fide  third parties' rights.  
3. Notwithstanding the provisions of Clause (2) above, FTA shall have the right to carry out the procedures of storage, transfer, retention, disposition, destroy, recycling or sale of 
seized perishable, d iminishable or leakable items, or would otherwise affect the safety of 
other goods and facilities in the same, along with disposing of left goods.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  19 
 4. Any actions taken by FTA on the seized items shall not prejudice the liability for paying 
the Payable Tax or the Administrative Fines, pursuant to the provisions of this 
Decree- Law or the Tax Law.  
5. The holder of right to seized items may request to rec over the same after paying the full 
Tax, Administrative Fines and expenses due thereon, as the case may be.  
6. Neither FTA nor its employees may be held liable f or malfunction or damage to the items 
seized as a result of FTA's disposition thereof under this Article.  
7. The Executive Regulations shall define the procedures and controls related to the application of Clauses (3), (4) and (5) above.

Article (27) 
Reconciliation on Tax Evasion Crimes  
1. Before a criminal action is instituted, FTA may enter into reconciliation on Tax Evasion 
crimes and the deliberate abstention from the payment of the Administrative Fines set 
forth in this Dec ree- Law or the Tax Law against the payment of the full Payable Tax and 
Administrative Fines. FTA may, before instituting a criminal action, reconcile the crimes set forth in Clause (4) of article (25) above after the amounts defined by the Executive 
Regula tions are paid.  
2. The Public Prosecution may, after the criminal action is instituted and before a judgment 
on conviction is rendered, order reconciliation on the crimes referred to in Clause (1) 
above against the payment of the full Payable Tax and Adm inistrative Fines, plus an 
amount equivalent to a percentage of the evaded Tax, as defined by the Executive 
Regulations, or the amounts defined by the Executive Regulations for the crimes set 
forth in Clause (4) of article (25) above.  
3. The Public Prose cution may, after a judgment on conviction is rendered, order 
reconciliation on the crimes referred to in Clause (1) above against the payment of the full Payable Tax and the Administrative Fines, plus an amount equivalent to a percentage 
of the evaded Tax , as defined by the Executive Regulations, or the amounts defined by 
the Executive Regulations for the crimes set forth in Clause (4) of article (25) above.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  20 
 4. The reconciliation under Clauses (2) and (3) above shall be after consulting FTA.  
5. The rec onciliation shall entail the lapse of criminal proceedings and the revocation of 
effects arising therefrom. The Public Prosecution shall order a stay of execution of the 
penalties imposed where the reconciliation is made during the execution thereof, even if the judgment has become final.  
6. The Executive Regulations shall define the conditions, controls and procedures of 
reconciliation set forth in this Article.  
  
Part Four  
Tax Assessment Review, Objection and Challenge 
Chapter One  
Application for Tax Assessment Review

Article (28) 
Application for Tax Assessment Review  
1. Without prejudice to the provisions of article (29) hereunder, any Person may submit an application to FTA for reviewing the Tax Assessment or part thereof issued  against the 
same and any associated Administrative Fines.  
2. The application submitted under Clause (1) shall be reasoned, and shall be submitted within (40) forty Business Days from the date on which the Person is notified of the Tax 
Assessment and the  associated Administrative Fines.  
3. FTA shall review the application submitted under Clause (1) above and shall be decided on within (40) forty Business Days from the date of receiving the said application. The 
applicant shall be notified of the decisio n within (5) five Business Days from the date of 
issuance.  
3. The Person may submit an application for reconsideration, pursuant to article (29) 
hereunder, against the decision issued under Clause (3) above, within (40) forty 
Business Days from the date of notifying the Person of the decision, pursuant to Clause 
(3) above, or expiry of the time limit within which FTA shall issue a decision on the 
application and so notify the applicant.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  21 
 5. No application for reviewing a Tax Assessment may be submitted or continued if a 
reconsideration application for which has been submitted.  
6. The application under Clause (1) above shall be submitted according to the form and mechanism identified by FTA.  
  
Chapter Two  
Application for Reconsideration

Article (29) 
Application for Reconsideration  
1. Any Person may submit an application to FTA for reconsideration of any decision or part 
thereof issued by FTA against such Person. The application shall be reasoned, and shall 
be submitted within (40) forty Business Days from the date on which the Person is 
notified of the respective decision.  
2. FTA shall consider and decide on the application by a reasoned decision within (40) forty 
Business Days from the date of receiving  the said application. The applicant shall be 
notified of FTA decision within (5) five Business Days from the date of issuance.  
3. An application for reconsideration on a Tax Assessment for which an application for 
review had been submitted to FTA may be submitted only after FTA issues a decision or expiry of the time limit within which FTA shall issue a decision on the application and so 
notify the applicant, pursuant to the provisions of article (28) and (35) above.  
4. The application under Clause ( 1) above shall be submitted according to the form and 
mechanism identified by FTA.  
  
  
 
Chapter Three  
Objection Submitted to the Committee

Article (30)  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  22 
 Tax Dispute Settlement Committee  
1. One or more standing committees to called "Tax Dispute Settlement Committee" shall 
be formed under the chairmanship of a member of the Judiciary and the membership of 
two experts from those enrolled in the Tax Experts Roll, who shall be appointed by a 
decision of the Minister of Justice in coordination with the Minister.  
2. The Cabinet shall issue a resolution on the Committee's rules of procedure, 
remunerations of its members and the applicable procedures.

Article (31) 
Competences of the Committee  
The Committee shall have the following competences:  
1. To decide on  objections filed against FTA's decisions on reconsideration applications.  
2. To decide on reconsideration applications submitted to FTA and no decision has been 
taken thereon, pursuant to the provisions of this Decree -Law.  
3. Any other competences assigned to the Committee by the Cabinet.

Article (32) 
Objection Submission Procedures and Cases of Objection Rejection  
1. An objection to the decision of FTA with regard to an application for reconsideration 
shall be submitted within (40) forty Business Days from the date of Notification of FTA 
decision.  
2. The objection submitted to the Committee shall not be accepted in t he following cases:  
a. If the application for reconsideration has not been submitted to FTA beforehand;  
b. If the full tax subject of the objection is not paid; and  
c. If the objection has not been submitted within the time limit set out in Clause (1 ) 
above.  
3. The Cabinet may, at the proposal of the Minister, issue a resolution for introducing any 
modifications to the amount of Payable Tax, pursuant to Paragraph (b) of Clause (2) 
above, for the purpose of submitting an objection under this Article.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  23

Article (33) 
Procedures of the Committee  
1. The Committee shall consider the objection submitted thereto and decide thereupon 
within (20) twenty Business Days from the date of receipt of the objection.  
2. The Committee shall notify the objecting Per son and FTA of its decision within (5) five 
Business Days from the issuance date thereof.  
3. The decision of the Committee shall be final in respect of the objection if the total 
amount of the Due Tax and the Administrative Fines specified therein does not exceed 
AED (100,000) one hundred thousand dirhams.  
4. In all cases, claims of tax disputes shall not be accepted before the Competent Court if 
the objection is not filed with the Committee beforehand.

Article (34) 
Enforcement of the Committee's Decisions  
1. Final decisions made by the Committee on disputes not exceeding AED (100,000) one hundred thousand dirhams shall be considered a writ of execution.  
2. Decisions made on disputes exceeding AED (100,000) one hu ndred thousand dirhams 
shall be considered a writ of execution if they are not challenged before the Competent 
Court within a period of (40) forty Business Days from the date of the objection result 
Notification.  
3. The Committee's final decisions having  the force of the writ of execution shall be 
enforced by the enforcement judge of the Competent Court.

Article (35) 
Extension of Time Limits  
1. FTA or the Committee, as the case may be, for any reason whatsoever, may extend any of the time limits set o ut in Clause (3) of article (28), Clause (2) of article (29) and Clause 
(1) of article (33) above for a period specified by the Executive Regulations.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  24 
 2. FTA or the Committee, as the case may be, at the request of any Person for any of the 
reasons specified in the Executive Regulations, may grant such Person an extension for 
any of the time limits set out in Clause (2) of article (28), Clause (1) of article (29) and 
Clause (1) of article (32) above.  
3. If the extension application submitted under Clause (2) above is rejected, pursuant to the 
provisions of article (32) or (36) of this Decree -Law, the decision of FTA or the 
Committee shall be final and irrevo cable or non -appealable, as the case may be.

Article (36) 
Appeal Proceedings Before Courts  
1. Without prejudice to the provisions of article (34) and (37) above, FTA  and the Person, 
as the case may be, may appeal against the decision of the Committee before the 
Competent Court within (40) forty Business Days from the date of notifying FTA or the 
Person, as the case may be, of the decision of the Committee in any of th e following 
cases:  
a. Objection to the committee's decision in whole or in part.  
b. No decision has been made by the Committee on an objection already submitted thereto in accordance with the provisions of this Decree -Law.  
2. The Competent Court shall adjudicate the inadmissibility of the appeal against FTA in the 
following cases:  
a. In the cases of objection rejection by the Committee, as set out in Clause (2) of Article 
(32) above.  
b. The Person's failure to provide a doc ument proving the full payment of Tax to FTA.  
c. The Person's failure to provide a document proving the payment of a percentage not less than (50%) of the Administrative Fines prescribed according to the Committee's decision or the court judgment, as the  case may be, through the cash payment to FTA 
or by providing an accredited bank guarantee in favour of FTA.  
3. The Cabinet may, at the proposal of the Minister, introduce any modifications to the 
amount set out in Paragraph (b) and the percentage set ou t in Paragraph (c) of article (2) 
above.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  25

Article (37) 
Special Procedures for Objection and Appeal  
Notwithstanding the provisions of Articles (31), (32), (33), (34) and (36) above, the Cabinet 
shall issue, at the proposal of the Minister, a reso lution approving an alternative mechanism 
for objection and appeal if parties to a dispute are any of the federal or local government 
authorities set out in this Resolution. Until the said Cabinet resolution is issued and entered 
into force, the provisions set forth in this Decree -Law shall apply to objections or appeals 
filed by federal and local government authorities related to Tax disputes.  
  
Part Five  
Tax Recovery and Collection  
Chapter One  
Recovery of Tax

Article (38) 
Tax Recovery Application  
1. The  Taxpayer may submit an application for recovery of any Tax he has paid if the same 
is entitled to recover such Tax in accordance with the Tax Law and it is found out the 
amount already paid exceeds the Payable Tax and the Administrative Fines, in 
accordan ce with the procedures specified by the Executive Regulations.  
2. FTA shall review the application submitted under Clause (1) and shall notify the 
Taxpayer of its decision approving rejecting the application.

Article (39) 
Tax Refund Procedures  
1. FTA shall make a set -off between the amount required to be refunded and any other 
undisputed Payable Tax or Administrative Fines of the Taxpayer applying for the 
recovery, in accordance with the Tax Return or Tax Assessment issued by FTA before the 
refund of any amount related to a particular Tax.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  26 
 2. FTA may abstain from refunding any amount mentioned in Clause (1) of this Article in 
any of the following cases:  
a. If it finds out that there are other disputed Tax amounts related to such Taxpayer.  
b. If the Person is subject to Tax Audit. In such a case, FTA may not abstain from refunding the outstanding amount following the fulfillment of the conditions 
identified by FTA Board resolution.  
c. By virtue of a decision by the Competent Court.  
3. FTA s hall refund the Tax under this Article in accordance with the procedures and 
controls specified by the Executive Regulations.  
  
Chapter Two  
Tax Collection

Article (40) 
Collection of Payable Tax and Administrative Fines  
1. If the Person fails to pay the Payable Tax within the time limits specified in this 
Decree- Law and the Tax Law, the following actions shall be taken:  
a. FTA shall serve a Notification to the Person for payment of the Payable Tax and the 
Administrative Fines within (20) twenty Business Days from the date of notification.  
b. In case the Person fails to make the payment after being notified in accordance with Paragraph (a) of Clause (1) of this Article, the Director -General shall issue a decision 
obligating the Person to pay the Payable Tax and the Administrative Fines, and such decision shall be notified within (5) five Business Days from the date of the decision, accompanied by the Tax Assessment and the assessment of Administrative Fines.  
c. The decisi on of the Director -General on the Tax Assessment and assessment of 
Administrative Fines shall be considered as a writ of execution for the purpose of 
enforcement by the enforcement judge of the Competent Court.  
2. If FTA finds out that the Payable Tax am ounts could be lost, the Director -General may 
ask an interim relief judge of the Competent Court to issue an order on petition to attach 
at the Person's property, at the possession of any one, adequate to collect such amounts. 
Such amounts shall be under a precautionary attachment and may be disposed of only if  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  27 
 the attachment is lifted by a judgment by the Competent Court at the request of the 
Director -General.  
3. The Tax and other amounts payable to FTA under the Tax Law shall take precedence over all fu nds of debtors thereof or Persons bound to pay the same to FTA under the 
Law, based on the priority over all other debts, other than legal expenses.  
4. Any Person who receives any amount as Tax, shall pay the same to FTA, and shall be treated with the same treatment of the Payable Tax.  
  
Chapter Three  
Payment and Collection of Tax and Administrative Fines in Special Cases

Article (41) 
Liability for Paymen t of Tax and Administrative Fines in Case of Partnership  
 Without prejudice to any provisions in the Tax Law, if multiple Persons participate in 
business that do not have an autonomous legal personality, each of them shall be held liable before FTA, severa lly and jointly, for the Payable Tax and the Administrative Fines for such 
business.

Article (42) 
Liability for Tax Payment in case of Partnership  
Without prejudice to any provisions in the Tax Law, if multiple Persons participate in business tha t do not have an autonomous legal personality, each of them shall be held liable 
before FTA, severally and jointly, for the Payable Tax and the Administrative Fines for such 
business.

Article (43) 
Payment of Tax and Administrative Fines in Special Cases  
1. The amount of Payable Tax shall be paid in cases of death as follows:  
a. For the Payable Tax of a natural Person prior to the date of his death, the Tax amount 
shall be paid from the elements of the estate or of the inc ome generated from such  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  28 
 estate before payout to the heirs or legatees.  
b. If, after the estate is apportioned, it is founds out there is an outstanding Payable Tax, 
the heirs and the legatees shall be held liable within their respective shares for 
paymen t the Payable Tax, unless a certificate of discharge has been obtained from 
FTA for the estate representative or any heir.  
2. The Payable Tax and the Administrative Fines of the Taxable Person who is incapacitated or with reduced capacity, missing, lost or of unknown domicile and the like shall be paid by his legal representative from assets and property of the Taxable Person, subject to the 
legislation in force in this regard.

Article (44) 
Payment and Administrative Fines of Tax in Case of Bankruptcy  
1. An appointed bankruptcy trustee shall communicate with FTA to inform him of the Due 
Tax or FTA's desire to conduct a tax audit for the specified Tax Period(s).  
2. FTA shall inform the bankruptcy trustee of the amount of the Payable Tax or the tax aud it within (20) twenty Business Days following the receipt of the notification of the 
bankruptcy trustee.  
3. The bankruptcy trustee has the right to appeal, object to and challenge the assessment of 
FTA or payment of the Due Tax.  
4. The Executive Regulations shall specify the procedures for communication with FTA, 
grievance, objection and payment of the Due Tax.  
  
Part Six 
General Provisions  
Chapter One  
Confidentiality and Conflict of Interest

Article (45) 
Professional Confidentiality  
1. Employees of FTA shall not disclose the information obtained or accessed to in their  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  29 
 professional capacity or on account thereof during their work, except as determined or 
defined in accordance with the Executive Regulations.  
2. In all the cases re ferred to in Clause (1) above, disclosure may only be made after the 
approval of the employees authorized by the Board of Directors of FTA, as defined by the Executive Regulations.  
3. Employees of FTA shall, upon completion of their services, maintain their professional confidentiality and not to disclose the information they obtained or accessed thereto due to their job capacity only at the request of judicial authorities and in accord ance with the 
Executive Regulations.  
4. Any Person who has obtained information in accordance with the provisions of the 
Decree- Law shall not disclose or use the information except for the very purpose for 
which it was obtained, without prejudice to the liability resulting therefrom, where 
necessary.  
5. The Board of Directors of FTA shall issue the regulations and instructions concerning the 
organization of internal procedures to protect the confidentiality of information in FTA 
and the obligations of t he Tax Agent in this regard.

Article (46) 
Conflict of Interests  
Any employee of FTA may not perform or engage in any tax procedures related to any 
Person in the following cases:  
1. In case of a kinship up to the fourth degree between the employee  and such natural 
Person;  
2. In case of a common interest between the employee and such natural Person or one of their relatives up to the third degree;  
3. In case of a personal or financial interest or any other relationship between the employee and such Person influencing the employee's ability to take an independent decision; and  
4. In case the Director -General decides not to carry out any Tax procedures  related to such 
Person for the presence of any other case of conflict of interest.   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  30 
   
Chapter Two  
Time Limits & Prescription

Article (47) 
Prescription  
1. Except for the cases set out in Clauses (2), (3), (6) and (7) hereunder, FTA may not 
conduct a Tax audit or issue a Tax Assessment on the Taxable Person after (5) five years 
from the end of the relevant Tax Period.  
2. FTA may conduct a Tax Audit or issue a Tax Assessment on the Taxable Person after (5) five years from the end of the relevant Tax Period if they are notified of the 
commencement of such Tax Audit prior to the lapse of the (5) five -year period; provided 
that the Tax Audit or the Tax Assessment issuance, as the case may be, within (4) four 
years from the date of the Tax Audit Notification.  
3. FTA may conduct a Tax Audit or issue a Tax Assessment after (5) five years from the end 
of the relevant Tax Period if such Tax Audit or the Tax Assessment issuance is related to a 
Voluntary Declaration that had been submitted in the fifth year of the end of the Tax 
Period; provided that the Tax Audit is made or the Tax Assessment is issued, as the case 
may be, within on e year from the date of submitting the Voluntary Declaration.  
4. The Cabinet, at the proposal of the Minister, may issue a resolution amending the time limit set for the completion of the Tax Audit or the issuance of the Tax Assessment, 
pursuant to Claus es (2) or (3) above.  
5. No Voluntary Declaration may be submitted following the lapse of (5) five years from 
the end of the relevant Tax Period.  
6. In case of Tax Evasion, FTA may conduct a Tax Audit within (15) fifteen years from the 
end of the Tax Period during which the Tax Evasion occurred.  
7. In case of non -tax registration, FTA may conduct a Tax Audit or issue a Tax Assessment 
within (15) fifteen years from the date on which the Taxable Person was required to 
make the tax registration.  
8. The prescription set forth in this Article shall cease for any of the reasons set forth in Federal Law No. (5) of 1985, Enacting the Law of Civil Transactions or any superseding  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  31 
 federal law.

Article (48) 
FTA's Right to Claim Payment  
The Payable Tax and A dministrative Fines, which have been notified to the Taxable Person, 
shall not lapse by prescription and may be claimed by FTA at any time.

Article (49) 
Time Limit for Tax Obligations  
Unless a specific time limit is set for the performance of any obligat ion or any other action in 
this Decree -Law or the Tax Law, FTA shall grant the Taxable Person a time limit for this 
purpose compatible with the nature of the obligation or the procedure of not less than (5) 
five Business Days and not more than (40) forty B usiness Days from the date of the incident 
leading to the occurrence of the obligation or action. FTA may extend such time limit.

Article (50) 
Calculating the Time Limits  
In all cases, the following rules shall apply upon calculating the time limits:  
1. The Notification day or the day on which the incident for which the time limit occurred is not included in the time limit.  
2. If the last day of the time limit is not a Business Day, the time limit shall be extended to 
the subsequent first Business Day . 
3. The time limits and dates set forth in this Decree -Law and the Tax Law shall be 
calculated according to the Gregorian calendar.

Article (51) 
Controls of Administrative Fines Payment in Installments, Exemption and 
Refund   
Federal Decree- Law No. (28) of 2022  on Tax Procedures  32 
 1. If FTA l evies or collects an Administrative Fine from any Person for violating the 
provisions of this Decree -Law or the Tax Law, the Committee set out in Clause (2) 
hereunder may, at the proposal of the Director -General, issue a decision approving the 
payment of the Administrative Fine amount in installments or exemption from or 
refunding, in whole or in part, such amount, in accordance with the controls and 
procedures issued by virtue of a Cabinet resolution, at the proposal of the Minister.  
2. FTA Board Chairman shall issue a resolution forming the Committee set forth in Clause 
(1) above under his chairmanship or his deputy and membership of two members of the 
Board. The resolution forming the Committee shall provide for the Committee's working 
system and the me thod of holding its meetings.  
  
Chapter Three  
Miscellaneous Provisions

Article (52) 
Proving the Authenticity of Data  
The burden of proving the Tax Retur n authenticity shall lie with the Taxable Person. In cases 
of Tax Evasion, the burden of proof shall lie with FTA.

Article (53) 
Judicial Police  
The Director -General and Persons designated under a resolution of the Minister of Justice, in 
agreement with t he Minister, shall have the capacity of judicial officers for detecting crimes 
or violations against the provisions of this Decree -Law, the Tax Law or resolutions issued in 
implementation thereof.

Article (54) 
Tax Resident  
1. For the purpose of the Tax Law or any convention or arrangement to which the State is a 
party, the Cabinet shall issue a resolution, at the proposal of the Minister, establishing  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  33 
 the conditions whereby a Person can be deemed a Tax Resident.  
2. FTA shall issue the Tax Domicile Cer tificate for the Tax Resident pursuant to the 
provisions established by the Cabinet resolution.

Article (55) 
FTA Fees  
By vir tue of a Cabinet resolution, at the proposal of the Minister, the fees payable to FTA 
shall be identified, pursuant to the provisions of this Decree -Law and the Executive 
Resolution thereof.

Article (56) 
Repeals  
1. Federal Law No. (7) of 2017, on Tax Procedures, as amended, shall hereby be repealed.  
2. Any provision contradicting or repugnant to the provisions of this Decree -Law shall 
hereby be repealed.  
3. The Executive Regulations of Federal Law No. (7) of 2017, on Tax Procedures, as 
amended, and any other resolutions issued in implementation thereof shall hereby be 
repealed, in so far as they do not contradict the provisions of this Decree -Law, until the 
superseding Executive Regulations and resolutions are issued, pursuant to the provisions of th is Decree- Law.

Article (57) 
Executive Regulations  
The Cabinet shall issue, at the proposal of the Minister, the Executive Regulations of this Decree- Law.

Article (58) 
Publication and Entry into Force of the Decree- Law  
This Decree- Law shall be published in the Official Gazette, and shall enter into force as of 1st  
Federal Decree- Law No. (28) of 2022  on Tax Procedures  34 
 March 2023. 
  
   
Mohammed bin Zayed Al Nahyan  
President of the United Arab Emirates  
  
Issued at the Presidential Palace – Abu Dhabi  
Dated: 4 th Rabi' al -Awwal 1444 AH,  
Corresponding to: 30 th September 2022 AD