FTA tax audits for groups: CT, VAT and the deadlines

The short answer

The FTA must notify you at least 10 business days before a tax audit (Article 16 of the Tax Procedures Law). It can audit a tax period for five years after it ends, or longer in specific cases. When the audit ends with a tax assessment, you have 40 business days to ask for a review or a reconsideration. Each later step, the objection to the Tax Disputes Resolution Committee and the appeal to court, has its own 40-business-day deadline.

For a group, the risk is less any single finding than inconsistency: one entity's VAT return, another's Corporate Tax return and the transfer pricing file telling different stories. Prepare as one group, with one coordinator.

What the FTA can do

You have the right to see the auditor's identification, receive a copy of the audit notice, attend an audit held outside the FTA, and get copies of documents taken (Article 21). You must cooperate (Article 20), and obstruction is itself penalised.

• Audit at its own premises, at your place of business, or wherever you store goods or keep records.
• Take original records or copies, and samples of goods or assets.
• Enter without notice, and close the premises for up to 72 hours, only with the Director General's written approval and where there are serious grounds, such as suspected evasion or obstruction.
• Re-audit a period it has already audited if new information comes to light, within the time limits.

Time limits and records

• Five years from the end of the tax period, as the general limit for an audit or assessment (Article 46).
• Four more years to finish, if the audit was notified before the five years ran out.
• Fifteen years in cases of tax evasion, or from the date you should have registered if you failed to register.
• No voluntary disclosure can be made more than five years after the end of the tax period.
• Corporate Tax records: seven years after the end of the tax period (Article 56 of the Corporate Tax Law). VAT records: at least five years, and fifteen for real estate.
• Transfer pricing: the master file, local file or any arm's length evidence is due within 30 days of an FTA request (Article 55 of the Corporate Tax Law).

After the audit: the dispute route and its deadlines

Under Article 49, the day of notification does not count, and a deadline falling on a non-business day moves to the next business day. Extensions are possible for reasons set out in the Executive Regulation, but a refusal is final, so do not plan on one. The objection deadline calculator counts the business days for you.

• Tax assessment review (Article 28, added in 2025): ask the FTA to review an assessment and its penalties within 40 business days of notification. The FTA decides within 40 business days and notifies you within 5. You can then ask for reconsideration within 40 business days.
• Reconsideration (Article 29): ask the FTA to reconsider any decision within 40 business days of notification. It decides within 40 business days, with reasons, and notifies you within 5. You cannot request reconsideration of an assessment while a review of it is pending.
• Objection to the Tax Disputes Resolution Committee (Article 32): within 40 business days of the reconsideration decision. The tax must be paid in full first. The Committee decides within 20 business days, and its decision is final where tax and penalties together do not exceed AED 100,000.
• Appeal to court (Article 36): within 40 business days of the Committee's decision. The tax must be paid in full, and at least 50% of the penalties paid or covered by a bank guarantee.

Preparing a group

The single-entity view of a VAT audit, including the documents the FTA asks for and the findings it raises most often, is in the FTA VAT audit guide.

• Name one coordinator for all FTA contact, and keep one log of every request, deadline and document provided.
• Reconcile before you are asked: VAT turnover to Corporate Tax revenue for each entity (the bridge), and intercompany balances on both sides.
• Check the transfer pricing file against the ledger: agreements, rates and charges as booked, especially intercompany loans and management fees.
• Test a sample of input VAT invoices against the Article 59 checklist and the supplier checks now required.
• Fix what you find through a voluntary disclosure before the audit is notified. A disclosure made after notification usually carries higher penalties.
• Make sure the same answer is given for the same question in every entity. Inconsistency across a group is what widens an audit.

How Hysaab applies this

Hysaab keeps each entity's invoices, ledger and VAT return working linked, tests invoices as they arrive, and compares VAT turnover with book revenue for each entity. When an audit notice arrives, the reconciliations the FTA will build already exist, by entity and by period.

Questions people actually ask

Keep reading

• Tool: FTA objection deadline calculator (40 business days)
• Guide: FTA VAT audit: what actually happens, and how to prepare your records
• Guide: VAT voluntary disclosure in the UAE: when Form 211 is mandatory, and what it costs by year
• Guide: UAE Corporate Tax penalties: what late registration, filing and payment actually cost
• Guide: Transfer pricing documentation in the UAE: who files what, and when