FTA Decision FTA Decision No. 9 of 2025 Federal Tax Authority

FTA Decision 9/2025 — Declining refunds of residual amounts during a tax audit

Federal Tax Authority Decision No. 9 of 2025 on the Conditions for Declining the Refund of the Residual Amounts related to a Refund Request where the Person is subject to Tax Audit

In force Issued 4 December 2025 In force from 1 January 2026

Official Arabic text (opens in a new tab) English translation (unofficial) (opens in a new tab)

Official Arabic title
قرار الهيئة الاتحادية للضرائب رقم (9) لسنة 2025 — شروط الامتناع عن رد المبالغ المتبقية المتعلقة بطلب استرداد في حال خضوع الشخص للتدقيق الضريبي
Document type
FTA Decision
Number
9
Issued by
Federal Tax Authority
Issued
4 December 2025
In force from
1 January 2026
Applies to
Persons with a refund request that are subject to an FTA tax audit, for any tax the FTA administers.
Current position
In force from 1 January 2026. Issued 4 December 2025 by the Chairman of the FTA Board.
Topics
Tax Procedures & the FTA · FTA audit
Official text
Official Arabic text · English translation (unofficial)

Factual summary

Lets the FTA withhold the residual amounts of a refund request while the person is under a tax audit when any one of six conditions is met: audit evidence that significant tax liabilities may arise, grounds to suspect tax evasion by the person or in the supply chain of the goods concerned, outstanding tax returns for any tax, failure to provide requested audit information on time, or any failure to cooperate during the audit.

What it means in practice Professional insight

Who: businesses with refund claims pending while under audit. What to check: that all tax returns are filed, audit information requests are answered within the deadline, and supply-chain due diligence is documented, so that refunds are not withheld.

Key provisions

  • Art. 1 The FTA may decline to refund any residual amounts related to a refund request where the Person is subject to a Tax Audit, if any one of six conditions is met.
  • Art. 1(1)–(3) Sufficient evidence, from the information available through the audit, that significant tax liabilities may arise; sufficient grounds to believe the Person is involved in Tax Evasion; or sufficient grounds to believe the refund relates to Goods suspected of being part of Tax Evasion in the supply chain.
  • Art. 1(4)–(6) The Taxable Person has outstanding Tax Returns for any type of Tax; the Person fails to provide information requested for the audit within the specified timeline; or the Person fails to cooperate in any manner with his obligations during the audit.
  • Art. 2 Published in the Official Gazette; effective 1 January 2026.

What changed

  1. 4 December 2025 Issued
  2. 1 January 2026 In force

Relationship chain

Law → decisions made under it → amendments → guidance and announcements; oldest first within each level.

  1. 30 September 2022 Federal Decree-Law FDL 28/2022 — Tax Procedures Law In force — amended
    1. 11 June 2017 Federal Law FL 7/2017 — former Tax Procedures Law — Replaced by this law from 1 March 2023 Superseded
      1. 24 September 2017 Cabinet Decision CD 36/2017 — Former Tax Procedures Executive Regulation (repealed) — Executive Regulation of this law Repealed
      2. 1 May 2018 Cabinet Decision CD 23/2018 — Tax Disputes Resolution Committees — Made under it In force
      3. 28 December 2021 Cabinet Decision CD 105/2021 — Instalments, waiver and refund of administrative penalties — Made under it In force
      4. 2 September 2022 Cabinet Decision CD 85/2022 — Who is a UAE tax resident — Made under it In force (see Corporate Tax)
    2. 24 September 2017 Cabinet Decision CD 40/2017 — Administrative penalties: VAT, Excise Tax and Tax Procedures (schedule in force from 14 April 2026) — Made under it In force — amended
      1. 28 April 2021 Cabinet Decision CD 49/2021 — 2021 replacement of the tax penalty tables — Amends it In force
      2. 9 October 2025 Cabinet Decision CD 129/2025 — New tax penalty amounts from 14 April 2026 — Amends Art. 1 In force
    3. 10 July 2023 Cabinet Decision CD 74/2023 — Tax Procedures Executive Regulation — Executive Regulation of this law In force — amended
      1. 16 August 2023 FTA Decision FTA Decision 14/2023 — Extra conditions for a firm to register as a tax agent — Made under Art. 12(2)(d) In force
      2. 13 December 2023 FTA Decision FTA Decision 15/2023 — Annual CPD hours for individual tax agents — Made under it In force
      3. 15 January 2024 FTA Decision FTA Decision 1/2024 — Professional standards and black points for tax agents — Made under it In force
      4. 23 March 2026 Cabinet Decision CD 17/2026 — Amendments to the Tax Procedures Executive Regulation — Amends Arts. 3, 10, 18, 26, 28 In force
      5. 2 June 2026 FTA Decision FTA Decision 4/2026 — Keeping records as electronic copies or photocopies — Made under Art. 4(2) In force
    4. 19 July 2024 FTA Decision FTA Decision 5/2024 — When private clarification fees are refunded — Made under it In force
    5. 1 November 2024 FTA Decision FTA Decision 8/2024 — Correcting VAT return errors that do not change the tax due — Made under it In force (see VAT)
    6. 17 February 2025 FTA Decision FTA Decision 1/2025 — Extending deadlines for review and reconsideration requests — Made under it In force
    7. 13 March 2025 Ministerial Decision MD 64/2025 — Earlier e-invoicing service-provider accreditation (repealed) — Made under it Superseded (see E-Invoicing)
    8. 12 September 2025 Ministerial Decision MD 243/2025 — E-invoicing system — Made under e-invoicing provisions In force — amended (see E-Invoicing)
    9. 9 October 2025 Cabinet Decision CD 106/2025 — E-invoicing violations and penalties — Made under it In force (see E-Invoicing)
    10. 4 December 2025 FTA Decision FTA Decision 9/2025 — Declining refunds of residual amounts during a tax audit — Made under it In force
    11. 11 June 2026 FTA Decision FTA Decision 7/2026 — Disposal of seized and abandoned goods — Made under it In force

Official sources

Official Arabic text (opens in a new tab) English translation (unofficial) (opens in a new tab)

Related services: VAT Health Check · Corporate Tax

Last verified against official sources: 26 October 2026 · اقرأ بالعربية

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General information, not tax advice. Each record is checked against the official source; where they differ, the official Arabic text prevails.