UAE issues amendments to the Executive Regulations of the Tax Procedures Law

Background

The UAE Cabinet has issued Cabinet Decision No. 17 of 2026, effective from 1 April 2026, amending Cabinet Decision No. 74 of 2023 concerning the Executive Regulations of Federal Decree‑Law No. 28 of 2022 on Tax Procedures (Executive Regulation).

These Executive Regulations changes represent a further step in the development of the UAE tax procedures framework and follow the broader amendments to the UAE Tax Procedures Law that entered into force on 1 January 2026. We previously reported on those legislative amendments in our Gulf Tax Insights publication issued in December 2025. The article is available here: UAE Tax Procedures Law changes as per 1 January 2026 | DLA Piper.

While the amendments are largely procedural in nature, they are directly relevant to day‑to‑day tax compliance, documentation management, audit readiness, and the governance of tax refund claims.

Below is an overview of the key amendments to the Executive Regulations.

 

1. Extended record retention period in case of a pending refund application

A taxpayer must keep records for an additional two (2) years (beyond the standard retention period) where it has submitted a refund application and the Federal Tax Authority (FTA) has not issued a decision on that application. Accordingly, businesses should monitor historic refunds and may need to preserve the full supporting documentation for longer than previously expected.

2. Updated voluntary disclosure process relevant to tax refunds

The amendments set out a more explicit approach for refund-application errors that lead to an excessive refund amount. Namely, where a taxpayer becomes aware that a tax refund application submitted to the FTA is incorrect and results in a refund claim exceeding the correct amount, the taxpayer must take corrective action promptly.

In principle, a Voluntary Disclosure must be submitted within twenty (20) business days from the date the taxpayer becomes aware of the error.

However, if the incorrect refund arises from an error in a tax return or tax assessment, different rules apply depending on the amount involved:

• Where the excess refund exceeds AED10,000, a Voluntary Disclosure is required within twenty (20) business days.
• Where the excess refund is AED10,000 or less, the error may instead be corrected through the next available tax return (where possible). A Voluntary Disclosure is only required if the error cannot be corrected through a tax return.

3. Power to extend the seizure period for documents or assets

One of the amendments introduces an express provision allowing the FTA to extend the specified period for seizing documents or assets, provided that the person concerned is notified, where possible. While the practical use of this power will be fact-dependent, it reinforces the FTA’s ability to preserve evidence where an audit requires additional time.

4. Credit balance refund procedures

The FTA is required to decide on a refund application and notify the taxpayer within twenty (20) business days from the date of submission, or within any other period required to decide the application, provided the taxpayer is duly notified. Where a refund is approved, the FTA must initiate the repayment procedures within five (5) business days from the date the taxpayer is notified of the approval.

5. Revised confidentiality and disclosure framework for sharing information with government entities

The amended provision places greater emphasis on the disclosure of information to a competent government entity which information may be disclosed pursuant to a formal agreement concluded with the authority. Such agreement ensures confidentiality and data protection, clearly defines the permitted use of the information, and sets out the procedures governing information control, security, subsequent disclosure, and data accuracy. This approach is consistent with broader public‑sector trends toward more formalized and robust information‑sharing governance.

 

Key takeaway

Recent updates to the Executive Regulations of the Tax Procedure Law introduces changes that, in practice, touch several core compliance and controversy areas.

In particular, taxpayers should consider (i) the new record retention extension linked to pending refund applications, (ii) the updated voluntary disclosure framework relevant to tax refunds, (iii) the authority’s ability to extend the period for seizing documents or assets, (iv) the clarified refund processing timelines, and (v) the more formalized confidentiality and information-sharing conditions for disclosures to competent government entities.

 

Reference / Link to document

• Executive Regulation of Federal Decree-Law No. 28 of 2022 on Tax Procedures