FTA penalty reconsideration — a well-argued request, on time
An FTA penalty is not always the end of the matter. Where there are genuine grounds, a reconsideration request can lead to the penalty being reduced or cancelled — but only if it is filed within the deadline and supported by evidence.
How the process works
| Request for reconsideration | Within 40 business days of being notified of the FTA decision |
| FTA decision | The FTA reviews the request and notifies its decision through EmaraTax |
| If rejected | An objection can be filed with the Tax Disputes Resolution Committee within 40 business days; the disputed tax generally has to be paid first |
| Further appeal | To the courts, in cases above the legal threshold |
The 40-business-day deadline is strict. Extensions are allowed only in limited, documented circumstances, so the request should be prepared as soon as the notice arrives.
What makes a request credible
- A clear chronology of what happened and when, supported by documents.
- The legal basis: why the penalty should not apply, or should be reduced.
- Evidence that the underlying issue has been corrected — for example the registration filed or the return amended.
- A professional, factual tone. Requests that rely only on hardship are less likely to succeed.
Some penalties can also be waived under specific schemes, such as the Corporate Tax late-registration waiver explained in our article.
How we help
- We review the penalty notice, your records and the timeline, and tell you clearly whether we see grounds for a request.
- We draft the reconsideration request with the supporting documents and the legal basis, and submit it within the deadline.
- We fix the underlying compliance issue at the same time, so the position is clean going forward.
- Our team supports clients with FTA cases and assessments, including cross-border and related-party matters, and can help prepare for the next stage if a request is rejected.
No adviser can guarantee the outcome of a reconsideration request; the decision rests with the FTA.
Sources: Federal Decree-Law No. 28 of 2022 on Tax Procedures, as amended (Articles 29 to 33); FTA Decision No. 1 of 2025 (extension of the reconsideration deadline); Cabinet Decision No. 10 of 2024 and related FTA guidance on the Corporate Tax late-registration penalty waiver.
Frequently asked questions
What is the deadline for a reconsideration request?
40 business days from the date you are notified of the FTA decision on EmaraTax — not from the date you read it. After that, the right is generally lost unless an extension is granted in limited circumstances.
Do I have to pay the penalty before asking for reconsideration?
Not for the reconsideration request itself. If the matter goes to the Tax Disputes Resolution Committee, the disputed tax generally has to be paid first.
Can a late-registration penalty be challenged?
Sometimes. It depends on the facts and on whether a waiver scheme applies. We review your case before recommending a route.
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