A reconsideration request is your formal appeal to the Federal Tax Authority against a decision it has issued against you, such as a tax assessment, an administrative penalty, or a registration rejection. You have 40 business days from the date you are notified of the FTA decision to file, and the FTA has up to 40 business days to respond (current FTA guidance allows extensions to 45 business days), followed by 5 business days to notify you of the outcome. Miss the window and you generally lose the right to challenge that specific decision through this route.
What a Reconsideration Request Actually Is
Under Federal Decree-Law No. 28 of 2022 on Tax Procedures (which replaced Federal Law No. 7 of 2017, effective from 1 March 2023, with its Executive Regulation issued as Cabinet Decision No. 74 of 2023), any person the FTA has issued a decision against has the legal right to ask the Authority to reconsider that decision. This covers a VAT or Corporate Tax assessment, an administrative penalty (late registration, late filing, late payment, or a voluntary disclosure penalty), a rejection of a registration or deregistration application, or a refund decision you disagree with.
A reconsideration request is not a courtroom appeal. It is an internal review, decided by the same authority that issued the original decision, which makes it faster and cheaper than escalating to the Tax Disputes Resolution Committee (TDRC) or the courts. Because the FTA is reviewing its own decision, the strength of your documentary evidence matters more than procedural argument alone.
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Who Can File, and the 40-Business-Day Deadline
You do not have to file personally. The request can be submitted by the taxable person, a registered tax agent, a legal representative or authorized signatory holding valid Power of Attorney or Memorandum of Association authority, or the representative member where the decision concerns a Tax Group. Whoever files must prove that authority; a submission without documented authorization is a common reason for rejection before the substance of the case is even reviewed.
The clock starts on the date you are notified of the FTA’s decision, not the date the decision is dated. The deadline runs in business days, so weekends and official UAE public holidays are excluded, which usually stretches a 40-business-day window to roughly 8 to 9 calendar weeks depending on where holidays fall. The table below sets out the full timeline from filing through to escalation.
| Stage | Responsible party | Statutory / published timeframe |
|---|---|---|
| File the reconsideration request | Taxpayer / tax agent / legal representative | 40 business days from notification of the FTA decision |
| FTA reviews and issues a decision | Federal Tax Authority | Up to 40 business days from receipt of a complete request (current EmaraTax guidance allows up to 45 business days, reflecting the extension provisions in FTA Decision No. 1 of 2025) |
| FTA notifies you of the outcome | Federal Tax Authority | Within 5 business days of the decision being made |
| Settle the disputed tax before objecting further | Taxpayer | Required before filing with the TDRC |
| Object to the Tax Disputes Resolution Committee | Taxpayer | 40 business days from receiving the reconsideration decision |
| TDRC issues its decision | Tax Disputes Resolution Committee | Up to 45 business days, extendable to 65 business days |
| Appeal to the competent court (disputes above AED 100,000) | Taxpayer | 40 business days from the TDRC decision notification |
Step-by-Step: How to File
- Confirm the notification date. Log in to EmaraTax and check the exact date the decision was issued to your account. This date, not today’s date, is what your 40-business-day window is measured against.
- Build your evidence file first. The FTA expects documentary proof supporting the factual and legal grounds of your case: the FTA decision itself, bank statements, tax return filing receipts, transaction records, contracts, and any relevant correspondence. Files are accepted in Word, Excel, PDF, JPG, PNG, or JPEG format, with a 5 MB limit per file.
- Submit through EmaraTax. Complete the reconsideration request form, attach your Power of Attorney or authorization documents if you are not the taxpayer, and set out your legal and factual grounds clearly. There is no government fee to submit a reconsideration request.
- Keep your submission receipt as proof of filing within the 40-business-day window if the timeline is ever disputed later.
- Track the FTA’s response window from the date your request was accepted as complete, and follow up through EmaraTax if you pass the 40 to 45 business day mark without a decision.
Worked Example: Mapping Your Own Filing Window
This is an illustrative example only, not a real case. Suppose the FTA issues a late VAT filing penalty of AED 20,000 and notifies the taxpayer through EmaraTax on 3 August. Counting only business days, 40 business days from that date lands the filing deadline in the first week of October. If the taxpayer submits a complete reconsideration request on 15 September, the FTA’s 40 to 45 business day response window runs from that date, so a decision could reasonably arrive between mid-November and early December, with formal notification following within 5 business days after that. If the taxpayer disagrees with the outcome, the 40-business-day window to escalate to the TDRC starts from the date the reconsideration decision is received, not from the original penalty date.
If the Reconsideration Is Rejected: What Comes Next
An unfavorable decision is not the end of the road. You have 40 business days from receiving it to object to the Tax Disputes Resolution Committee, but only after settling the disputed tax, which is a mandatory prerequisite for a TDRC objection. Where the total disputed tax and penalties do not exceed AED 100,000, the TDRC’s decision is final and binding. Above that threshold, either party can appeal to the competent court within 40 business days of the TDRC notification. Each stage carries its own 40-business-day clock, and missing one can close off further challenge to that assessment.
Frequently Asked Questions
Is there a fee to file a reconsideration request?
No. Submitting a reconsideration request through EmaraTax carries no government filing fee. Professional fees for a tax agent preparing the submission are separate.
Do I have to pay the disputed tax before filing a reconsideration request?
No. Payment is not a precondition at the reconsideration stage. Settlement of the disputed tax only becomes mandatory if you later escalate to the Tax Disputes Resolution Committee.
What happens if I miss the 40-business-day filing deadline?
You generally lose the right to challenge that decision through a reconsideration request. Extensions are only available in the limited circumstances set out under FTA Decision No. 1 of 2025, so do not plan around one being granted.
Can the FTA take longer than 40 business days to respond?
Yes. The Authority can extend its review period, and current EmaraTax guidance already reflects a working window of up to 45 business days. If you pass that point with no decision, follow up in writing and record the date.
Can a tax agent file the reconsideration request for me?
Yes. A registered tax agent, an authorized legal representative, or the representative member of a Tax Group can file on the taxpayer’s behalf, provided proof of authority is included.
What is the difference between a reconsideration request and the Tax Disputes Resolution Committee?
A reconsideration request is a mandatory first step, reviewed internally by the FTA itself. The TDRC is an independent committee you can only approach after an unfavorable reconsideration decision, and only once the disputed tax has been settled.
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How Tax Consultant Dubai Can Help
Our tax dispute resolution service prepares and files reconsideration requests, builds the supporting evidence file the FTA expects, and manages escalation to the Tax Disputes Resolution Committee where needed, so your 40-business-day deadlines are never missed.
Contact Tax Consultant Dubai today to have your case reviewed before your filing window closes.
