Cabinet Decision No. 17 of 2026 amends the UAE's Tax Procedures Executive Regulations (Cabinet Decision No. 74 of 2023). Issued on 23 March 2026 and effective from 1 April 2026, it is a targeted update — not a full replacement — that reshapes the rules on voluntary disclosures, tax refunds and credit balances, record retention, and the confidentiality of taxpayer information across VAT, Excise Tax and Corporate Tax.
Key takeaways
- Cabinet Decision No. 17 of 2026 amends the Tax Procedures Executive Regulations (Cabinet Decision No. 74 of 2023) with effect from 1 April 2026; provisions not expressly amended remain in force.
- It flows from Federal Decree-Law No. 17 of 2025, which amended the Tax Procedures Law (Federal Decree-Law No. 28 of 2022) with effect from 1 January 2026.
- A voluntary disclosure is no longer mandatory for every return error — where there is no tax difference, correction can usually be made through the return itself.
- Refund and credit-balance claims now carry a hard five-year limitation; missing it means permanent forfeiture. A one-time transitional window to 31 December 2026 covers older balances, including early VAT years (2018-2020).
- Where a refund is claimed in year five, records must be kept for up to seven years (five plus two) and the FTA gains an extra two-year audit window.
- The confidentiality rules are realigned with Cabinet Decision No. 209 of 2025 on exchange of information, tightening how receiving authorities may use disclosed data.
How the Tax Procedures instruments fit together
The amendment sits within a chain of instruments. The Tax Procedures Law (Federal Decree-Law No. 28 of 2022) is the core statute, in force since 1 March 2023. Federal Decree-Law No. 17 of 2025 amended that law with effect from 1 January 2026. Cabinet Decision No. 74 of 2023 was the original Executive Regulation, and Cabinet Decision No. 17 of 2026 now amends it. Crucially, the amendment applies uniformly to VAT, Excise Tax and Corporate Tax, and it leaves untouched every provision it does not expressly change.
| Date | Milestone |
|---|---|
| 1 January 2026 | Federal Decree-Law No. 17 of 2025 in force |
| 23 March 2026 | Cabinet Decision No. 17 of 2026 issued |
| 1 April 2026 | Cabinet Decision No. 17 of 2026 effective |
| 31 December 2026 | Transitional window closes |
Voluntary disclosures: lighter for zero-impact errors
A voluntary disclosure is no longer required for every return error: where an error produces no tax difference, it can, in most cases, be corrected through the tax return itself, with a formal disclosure needed only in circumstances the FTA specifies. The five-year bar on voluntary disclosures is retained, now codified with precision and aligned with Article 10 of the amended Tax Procedures Law. The 20-business-day trigger — filing within 20 business days of becoming aware of an under-declaration or over-stated refund — remains, with the form and manner to be set by the FTA. A narrow new exception even allows a disclosure beyond the five-year bar where it relates to a refund application filed during the transitional window, provided the FTA has not yet issued its decision and it is filed within two years of the application.
Refunds and credit balances: a hard five-year clock
A hard five-year limitation now applies to refund and credit-balance claims, running from the end of the relevant tax period; miss it, and the refund right is permanently forfeited. The scope is also broadened — it now expressly reaches any credit balance in the taxpayer's favour, including balances arising from FTA decisions, not just the previously enumerated triggers. Where a refund application is filed in year five of that period, the FTA receives an additional two-year window to audit or assess the claim.
The transitional window is a use-it-or-lose-it deadline. Any VAT credit balance from the early years of the regime — 2018 to 2020 — whose five-year claim period has already lapsed, or lapses within a year of 1 January 2026, must be claimed by 31 December 2026, or the refund right is gone for good.
Record retention: plan for up to seven years
The baseline retention period is unchanged at five years from the end of the relevant tax period, and the one-year rule for a Legal Representative after their representation ends is also unchanged. What is new is an extended-retention trigger: where a refund application is filed before the five-year limitation expires and the FTA has not yet decided, records must be kept for an additional two years — a maximum of seven years for tax periods with a pending refund claim. Destroying records at year five while a refund is undecided can prejudice the claim and attract administrative penalties, so retention policies should be updated now. In practice, SBC advisers flag the year-five refund claim as the moment retention quietly extends to seven years, a trap for groups that purge records on a fixed five-year cycle.
Confidentiality realigned with the information-exchange rules
The amendment revises the disclosure and confidentiality framework and realigns it with the amended Tax Procedures Law and Cabinet Decision No. 209 of 2025 on Exchange of Information upon Request. The scope of permissible disclosure is more precisely defined, and restrictions on how receiving government authorities may subsequently use information are explicitly codified — information cannot be repurposed outside its stated objective. Existing FTA confidentiality obligations are reaffirmed and now read alongside the international-cooperation framework.
Action points for businesses
- Audit historical VAT credit balances from 2018-2020 and claim any at-risk balances by 31 December 2026 through VAT advisory support.
- Extend record-retention schedules to seven years for any tax period with a pending, undecided refund — a control worth embedding in a tax automation process.
- Revise voluntary-disclosure procedures so zero-impact errors are corrected through the return rather than a formal disclosure.
- Prepare for the extended FTA review window on year-five refund claims by keeping documentation audit-ready, with help from our audit and disputes team.
Frequently asked questions
When does Cabinet Decision No. 17 of 2026 take effect?
Cabinet Decision No. 17 of 2026 was issued on 23 March 2026 and takes effect on 1 April 2026. It amends the Tax Procedures Executive Regulations (Cabinet Decision No. 74 of 2023) and applies to VAT, Excise Tax and Corporate Tax.
Do I still need to file a voluntary disclosure for every error?
No. Where an error produces no tax difference, it can usually be corrected through the tax return itself. A voluntary disclosure is required only where a tax difference arises or in circumstances the FTA specifies.
What is the deadline to claim old UAE VAT refunds?
Credit balances whose five-year claim window has expired, or expires within one year of 1 January 2026, must be claimed by 31 December 2026. This one-time transitional window squarely covers early VAT years from 2018 to 2020.
How long must UAE businesses keep tax records now?
The standard period remains five years from the end of the relevant tax period. Where a refund application is pending and undecided, records must be kept for an additional two years — up to seven years in total.
How SBC Tax Consulting can help
SBC helps businesses act on Cabinet Decision No. 17 of 2026 before the deadlines bite. We audit historical VAT credit balances and file transitional claims, update record-retention and voluntary-disclosure procedures, and align VAT and corporate tax controls with the amended regulations. To review your exposure ahead of 31 December 2026, contact our team.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.