United Arab Emirates: Amendments to the Tax
Procedures Law to Take Effect in Early 2026

The UAE Ministry of Finance has issued Federal Decree-Law No. (17) of 2025 amending certain provisions of Federal Decree-Law No. (28) of 2022 on Tax Procedures. The amendments aim to enhance the efficiency of the tax system and strengthen transparency and fairness in tax administration. The new provisions will enter into force on 1 January 2026.

Enhancing Financial Discipline

The amendments establish a clearer and more structured framework governing the obligations and procedures between taxpayers and the Federal Tax Authority (FTA). Tax refund requests must be submitted within five years from the end of the relevant tax period. Additional flexibility is granted in situations where the credit balance arises during the last 90 days of that period or after the limitation period has elapsed. This structure ensures clarity, predictability and protection of taxpayer rights.

Balance and Flexibility

The amendments expand the provisions related to limitation periods. In specific cases, the FTA may conduct tax audits or issue tax assessments even after the limitation period has expired. The purpose is to maintain a balance between safeguarding taxpayer rights and protecting the state’s financial interests. The amendments also grant the FTA the authority to issue official and binding directions to taxpayers and internal units regarding the interpretation and application of tax laws, thereby promoting uniformity and reducing risks arising from inconsistent treatment.

Transitional Provisions

The amended law introduces transitional rules for taxpayers with credit balances for which the five-year period expired before 1 January 2026 or will expire within one year after that date. These taxpayers may submit refund requests within one year from 1 January 2026. If the FTA has not issued a decision on the request, the taxpayer may file a voluntary disclosure within two years from the date of submission. This ensures fairness and provides a structured path for resolving previous cases.

Overall Assessment

The amendments reflect the UAE’s commitment to developing a modern, transparent and internationally aligned tax framework. By clarifying rights, strengthening procedures and reducing administrative burdens, the reform enhances trust in the tax system and supports sustainable public revenues and long-term economic growth.

https://mof.gov.ae/en/news/ministry-of-finance-to-implement-amendments-to-the-tax-procedures-law-starting-early-2026/