What is a voluntary disclosure in UAE tax, and when is it required?
Short answer
A voluntary disclosure is the form a taxpayer files with the FTA to correct an error in a tax return, a tax assessment or a tax refund application (Article 10 of the Tax Procedures Law). It applies to VAT, Excise Tax and Corporate Tax.
It is compulsory when the error means too little tax was paid or too much was refunded, and optional when the error went the other way. Errors that do not change the tax must also be corrected this way in the cases specified. A voluntary disclosure cannot be filed more than 5 years after the end of the tax period (Article 46, with a narrow exception for refund applications). The penalties differ depending on whether the disclosure is made before or after the FTA notifies a tax audit: see the administrative penalties decisions below.
What the law says
Federal Decree-Law No. 28 of 2022 on Tax Procedures, Article 10
Article 10
- If a Taxable Person becomes aware that a Tax Return submitted to the Authority or a Tax Assessment issued by the Authority is incorrect, which resulted in a calculation of Payable Tax according to the Tax Law being less than it should have been, the Taxable Person shall submit a Voluntary Disclosure.
- If a Taxpayer becomes aware that a Tax refund application submitted to the Authority is incorrect, which resulted in the calculation of a refund amount to which he is entitled according to the Tax Law being more than it should have been, the Taxpayer shall submit a Voluntary Disclosure.
- If a Taxable Person becomes aware that a Tax Return submitted to the Authority or a Tax Assessment issued by the Authority is incorrect, which resulted in the calculation of Payable Tax according to the Tax Law being more than it should have been, the Taxable Person may submit a Voluntary Disclosure.
- If a Taxpayer becomes aware that a Tax refund application submitted to the Authority is incorrect, which resulted in the calculation of a refund amount to which he is entitled according to the Tax Law being less than it should have been, the Taxpayer may submit a Voluntary Disclosure.
- If the Taxpayer discovers an error or omission in the Tax Return submitted to the Authority, where there is no difference in the amount of Due Tax, the Taxpayer must correct such error by submitting a Voluntary Disclosure in the cases specified by the Authority, or correct such error via a Tax Return in any other case.9
- The Executive Regulation shall set out the detailed provisions relating to submitting a Voluntary Disclosure to the Authority and the method of application of Administrative Penalties imposed prior to the Voluntary Disclosure.
8 Clause amended as per Federal Decree-Law No. 17 of 2025.
9 Clause amended as per Federal Decree-Law No. 17 of 2025.
Decisions and FTA guidance on this
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