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May 15, 2026

This Public Clarification details the amendments to the UAE Tax Procedures Law under Federal Decree-Law No. 28 of 2021, effective from 1 November 2021. It explains three key changes: extended timelines for taxpayers to submit reconsiderations, objections to the TDRC, and appeals to competent courts under Articles 27, 30, and 33; revised requirements for penalty payments before lodging appeals; and the establishment of a new committee under Article 46 to manage penalty waivers, refunds, and instalment plans. The clarification also notes a future alternative dispute mechanism for government entities under Article 32(bis).

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Tax Procedures Public Clarification

Amendment of Tax Procedures Law – Federal Decree-Law No. 28 of 2021

Issue

Tax procedures in the UAE are regulated by the Federal Law No. 7 of 2017 on Tax Procedures. The Federal Decree-Law No. 28 of 2021 on the Amendment of Some Provisions of the Federal Law No. 7 of 2017 on Tax Procedures ("Tax Procedures Law") has been issued, and is effective from 1 November 2021.

This Public Clarification is intended to inform persons of the changes in the Tax Procedures Law, in relation to three main changes:

1. Mechanism and requirements for objection and appeal by taxpayers;

2. Alternative mechanism for objection and appeal by Government entities; and

3. Mechanism of waiving, refunding, and payment of administrative penalties ("Penalties") as instalments.

Summary

The amendments to the Tax Procedures Law are effective from 1 November 2021, and mainly cover:

Mechanism and requirements for objection and appeal by taxpayers;

The tax procedures in the UAE include a mechanism to challenge decisions issued by the Federal Tax Authority ("FTA"). The decision dispute process starts with an application for reconsideration. If a person still disagrees after the FTA has issued its decision in respect of a request for reconsideration, the person may lodge an objection with the Tax Disputes Resolution Committee ("TDRC") and subsequently appealing before the competent court.

The changes in the Tax Procedures Law encompass two major aspects of change in relation to the procedures for objection and appeal, namely:

• Extension of the timelines within which a person may object or appeal against an FTA decision;

• Easement of requirements to pay Penalties, by removal of the requirement to pay such Penalties before access to TDRC and only requiring partial payment of Penalties before access to courts.

Alternative mechanism for objection and appeal by Government entities

As an exception to the general rules for objections and appeals to the TDRC and competent court, the Cabinet shall issue a Decision adopting an alternative mechanism of objection and appeal if the parties to the dispute are any of the Federal or local Government entities specified in that Cabinet Decision.

Pending the Cabinet Decision and its enforcement, the general objection and appeal rules will apply to objections and appeals of Federal and local Government entities concerning tax disputes.

Mechanism of waiving, refunding, and payment of Penalties as instalments