Taxation of Investors in a Real Estate Investment Trust: What You Must Know
19/07/2025
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As the United Arab Emirates (UAE) strengthens its tax infrastructure, the right to challenge decisions issued by the Federal Tax Authority (FTA) through a VAT reconsideration process has become increasingly important for business entities and taxpayers. This mechanism is embedded within the UAE Tax Laws and governed by the Federal Decree Law, Tax Procedures Law, and related executive regulations. It allows any taxable person to file a formal reconsideration request against decisions issued by the FTA, including penalties imposed, assessments, or other determinations.
VAT reconsideration serves as a vital remedy under UAE VAT Reconsideration protocols, helping businesses correct incorrect information, request clarification, and defend against non-compliance allegations. Whether you're a natural person, legal person, representative member of a tax group, or a registered tax agent, knowing how to file a valid reconsideration is essential.
VAT reconsideration is a statutory safeguard embedded in UAE tax law that allows taxpayers to apply for VAT reconsideration when they believe a decision issued by the FTA (Federal Tax Authority) is incorrect or unfair. By submitting a formal VAT reconsideration request via the EmaraTax application form and accompanied by all documents required, a taxable person can challenge determinations that impact their liabilities, from VAT penalties on late registration to disputed assessments of tax payable or rejected refund claims.
Under the relevant decree law, the FTA must review the filing within 20 business days from the date it is received, ensuring that every request is evaluated promptly. During this period, the authority may ask for additional evidence or clarifications; therefore, providing complete, well‑organised required documents is critical.
Because the stakes can include sizable fines or ongoing cash‑flow constraints, many businesses rely on specialized VAT reconsideration services. Seasoned tax experts can frame the legal arguments, reference precise statutory clauses, and highlight precedents to improve the odds of a favourable outcome. Beyond the core reconsideration, these professionals often advise on other services such as preventive compliance reviews, to minimise future discrepancies with the FTA.
Ultimately, UAE VAT reconsideration reinforces procedural fairness by granting every taxable person the right to seek correction through a recognised framework, while simultaneously supporting the FTA’s mandate for transparent and accurate collecting federal taxes.
The VAT reconsideration process plays a crucial role in upholding the integrity of the UAE’s tax laws, especially when a taxable person or tax group believes they have been subject to unfair treatment, incorrect assessments, or penalties imposed by the Federal Tax Authority (FTA). In such instances, submitting a well-supported reconsideration request allows the person concerned or their legal representative to challenge the decision without immediate court escalation.
By filing a VAT reconsideration request, businesses gain access to an administrative pathway for tax dispute resolution, providing the chance to correct factual errors, clarify misinterpretations, and submit new supporting documents within the allowed days from the date of the original decision. This review is handled by qualified tax professionals within the Federal Tax Authority, ensuring that every claim is examined in accordance with UAE tax procedures.
Moreover, this step is often a prerequisite before escalating matters to the Tax Dispute Resolution Committee or the Federal Court, making it an essential safeguard within the UAE’s framework for uae vat reconsideration. It reinforces confidence in the FTA’s commitment to fairness, transparency, and due process for all entities governed by the country’s tax laws.
The right to apply for VAT reconsideration in the UAE is grounded in a robust legal framework designed to uphold fairness and procedural accuracy in tax matters. This framework is primarily established through:
Federal Decree Law No. (8) of 2017 on Value Added Tax, which defines the scope, obligations, and application of value added tax (VAT) in the UAE.
Federal Law No. (7) of 2017 on Tax Procedures, which outlines the processes related to tax obligations, including filing a VAT reconsideration request.
Related Cabinet Decisions, implementing regulations, and FTA-issued guides that provide operational clarity on how reconsideration requests are submitted, processed, and resolved.
These legal references ensure that any taxable person or legal representative who wishes to contest penalties imposed or any administrative action by the Federal Tax Authority (FTA) can do so through an officially sanctioned channel. The VAT reconsideration form must be submitted within 20 business days from the date of the decision being contested, as mandated by the tax procedures law.
The Federal Tax Authority FTA considers such requests from both natural persons and legal persons in their capacity as members of a tax group, ensuring that every party has a fair chance to rectify or challenge decisions that may arise from misunderstanding, administrative error, or circumstances requiring clarification.
The VAT reconsideration services offered by registered tax agents help taxpayers correctly fill out the application and ensure that all required supporting documentation is submitted on time. Submitting a valid reconsideration request through the EmaraTax portal is the first critical step in the broader tax dispute resolution process, before escalating matters to the Tax Dispute Resolution Committee or the Federal Court, if necessary.
Whether challenging VAT penalties, seeking clarification on tax liabilities, or defending against allegations such as tax evasion, the UAE’s legal infrastructure supports transparency and procedural justice at every stage of the reconsideration process.
Submitting a VAT reconsideration request to the Federal Tax Authority (FTA) is a formal legal process that allows a taxable person or tax group to challenge a decision, administrative penalty, or assessment issued under UAE tax laws. Here's how eligible applicants can file a reconsideration request through the EmaraTax portal:
Begin by accessing the official EmaraTax system provided by the Federal Tax Authority. This is where the taxable person or legal representative can navigate to the “Reconsideration Application” section under their user dashboard.
Carefully review your issued notices and select the decision you are disputing, this could be a fine, penalty, or other tax ruling under UAE VAT laws. Make sure to note the reference number and the exact date the decision was issued, as you must submit the request within 20 business days from the date of notification.
Fill out the reconsideration request form with accurate information, including your Tax Registration Number (TRN), details of the tax group (if applicable), and a clear justification for why the FTA decision should be reviewed under UAE tax laws. This explanation must be legally sound and supported by tax procedure principles.
Attach all relevant documents to strengthen your case, this may include invoices, contracts, VAT returns, audit reports, financial statements, or any communication related to the VAT reconsideration. All documents must be translated into Arabic as per FTA regulations. Submissions in other languages without certified translations may lead to automatic rejection.
Review the completed form thoroughly. The request must be digitally signed or authenticated by the authorized tax agent or the taxable person themselves. After submission, the reconsideration application will be evaluated under the framework of Federal Law No. 7 of 2017 on Tax Procedures and Federal Decree-Law No. 8 of 2017 on Value Added Tax.
Once submitted, log in regularly to the EmaraTax system to track the status of your reconsideration request. Although the Federal Tax Authority typically issues a decision within 20 to 45 business days, the timeline may vary depending on the complexity of the issue and volume of documentation.
Engaging a registered tax agent or qualified legal representative is one of the most effective ways for taxpayers to apply for VAT reconsideration and improve their prospects of success. These professionals have deep expertise in UAE VAT reconsideration procedures, the statutory framework under Federal Decree‑Law No. (8) of 2017, and Federal Law No. (7) of 2017, laws that empower the Federal Tax Authority (FTA) to oversee collecting federal taxes.
Prepare a compelling, justified decision letter that aligns the VAT reconsideration request with the law and clearly rebuts the decision issued by the FTA.
Specify the exact documents required to support the request, including EmaraTax forms, tax returns, contracts, and evidence of late registration or miscalculated liabilities.
Translate all records into Arabic where necessary and upload them through the EmaraTax portal.
Submit the file within the mandated 20 business days (days from the date of the FTA notice), or risk procedural dismissal. In such cases of delay or non‑compliance, the agent can seek extensions only if the law permits.
Verify every statutory citation, cross‑reference the documents required, and confirm the FTA’s receipt number to avoid administrative rejections and further VAT penalties.
Track the FTA’s estimated time for review, up to within 45 business days and respond promptly to any requests for clarification.
A seasoned legal representative strengthens a VAT reconsideration case in three critical ways. First, they safeguard the file’s defensibility if the dispute must be escalated to the Tax Dispute Resolution Committee or ultimately the Federal Court, ensuring that every procedural requirement is satisfied in advance. Second, they identify and neutralise procedural traps, technical oversights or jurisdictional missteps, that could otherwise invalidate the reconsideration request on purely formal grounds. Finally, experienced counsel provides strategic advice on parallel compliance measures, helping the taxpayer plug any gaps that might expose the business to future penalties or non-compliance findings.
At Young & Right, we provide end‑to‑end VAT reconsideration services for individuals, companies, and tax groups across the UAE. Working closely with the Federal Tax Authority (FTA), the regulatory body that enforces the UAE’s VAT regime. We manage every stage of your VAT reconsideration request, ensuring full alignment with the relevant legal references such as Federal Decree‑Law No. (8) of 2017 and the Tax Procedures Law.
We examine your transactions from supply chain origin to end consumer impact to determine whether the facts support applying to apply for VAT reconsideration and to minimise future VAT penalties.
Our team compiles all required supporting documents, invoices, contracts, tax returns and completes the EmaraTax application form, translating and notarising each file where necessary.
We submit your electronic VAT reconsideration request through the EmaraTax portal, referencing every pertinent clause to meet the FTA’s strict filing standards.
When the FTA’s decision arrives, we analyse its legal basis and craft a detailed rebuttal or clarification grounded in statute and precedent.
We track the statutory clock, 20 business days from the date of the FTA notice and keep the process within the authority’s estimated timeframe to protect your right of appeal.
Beyond filing, we pinpoint weaknesses such as potential tax‑evasion red flags or procedural gaps to safeguard your organisation’s future compliance and preserve credibility with the FTA.
By entrusting your UAE VAT reconsideration to Young & Right, you gain a strategic partner committed to swift action, precise documentation, and favourable outcomes at every stage of the process.
Understanding and executing a VAT reconsideration request is critical for safeguarding your rights under UAE tax laws. With defined procedures, strict deadlines, and mandatory documentation, taxpayers must act with precision and professionalism.
By engaging experienced advisors and leveraging systems like EmaraTax, businesses can challenge unjust penalties, correct errors, and ensure compliance with the UAE’s robust tax framework.
Contact Young & Right today for expert guidance on your VAT reconsideration or any other services related to tax disputes, compliance, or regulatory alignment in the UAE.
Let Young & Right handle your FTA submission, legal documents, and EmaraTax filing accurately and on time. Protect your rights and avoid costly penalties.
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