GTL Summary:

Article 46 establishes the statute of limitation for tax audits and assessments by the Federal Tax Authority (FTA). Generally, the FTA cannot conduct an audit or issue an assessment more than five years after the end of a relevant tax period. Key exceptions exist: if an audit is notified within the five-year window, the FTA has four additional years to complete it. For Voluntary Disclosures or refund applications submitted in the fifth year, the Authority has one and two years respectively to act. For severe cases like tax evasion or failure to register, this period extends to fifteen years.

Document Type: Tax Law Article
Law: Tax Procedures (FDL No 28 of 2022, as amended)
Article Number: 46
Country: 🇦🇪 UAE
Location: Title 6 - General Provisions › Chapter 2 - Time Periods and Lapse of Time
Order: 46
Last updated at: 2026-02-20 14:31:33 UTC

Title 6 - General Provisions

Chapter 2 - Time Periods and Lapse of Time

Article 46 - Statute of Limitation [13], [14]

  1. Except in cases under [Clauses 2, 3, 4, 7 and 8][G14] of this Article, the Authority may not conduct a Tax Audit or issue a Tax Assessment to a Taxable Person after the expiration of (5) five years from the end of the relevant Tax Period.

  2. The Authority may conduct a Tax Audit or issue a Tax Assessment to the Taxable Person after (5) five years from end of the relevant Tax Period, if he has been notified of the commencement of such Tax Audit's procedures before the expiration of the (5) five year period, provided that the Tax Audit is completed or the Tax Assessment is issued, as the case may be, within (4) four years from the date of Notification of the Tax Audit.

  3. The Authority may conduct a Tax Audit or issue a Tax Assessment after the expiration of (5) five years from the end of the relevant Tax Period if such Tax Audit or Tax Assessment issuance relates to a Voluntary Disclosure submitted in the fifth year from the end of the Tax Period, provided that the Tax Audit is completed or the Tax Assessment is issued, as the case may be, within (1) one year from the date of submission of the Voluntary Disclosure.

  4. [The Authority may conduct a Tax Audit or issue a Tax Assessment after (5) five years from the end of the relevant Tax Period if the Tax Audit or the issuance of the Tax Assessment relates to a refund application related to Tax or credit balance submitted in the fifth year from the end of the Tax Period referred to in Clause 2 of Article 38 of this Decree-Law, or during the period referred to in Clauses 3 and 4 of Article 38 of this Decree-Law, as the case may be, provided that the Tax Audit is completed or the Tax Assessment is issued, as the case may be, within two (2) years from the date of the submission of the refund application.][G15]

  5. The Cabinet may, according to a suggestion by the Minister, issue a decision to amend the period specified for the completion of the Tax Audit or the issuance of the Tax Assessment as per [Clauses 2, 3 or 4][G16] of this Article.

  6. No Voluntary Disclosure may be submitted after the expiration of (5) five years from the end of the relevant Tax Period [, with exception of submitting a Voluntary Disclosure in accordance with Clause 2 of Article 10 of this Decree-Law, where the Voluntary Disclosure is related to a refund application for which the Authority has not yet issued a decision]. [15][G17]

  7. In the case of Tax Evasion, the Authority may conduct a Tax Audit or issue a Tax Assessment within (15) fifteen years from the end of the Tax Period in which the Tax Evasion occurred.

  8. In case of Tax Registration failure, the Authority may conduct a Tax Audit or issue a Tax Assessment within (15) fifteen years from the date on which the Taxable Person should have registered for Tax.

  9. The statute of limitation set forth in this Article shall be interrupted for any of the reasons provided for in the Federal Law No. 5 of 1985 promulgating the Civil Transactions Law, or any federal law replacing it.

Footnotes

[13]Article amended as per Federal Decree-Law No. 17 of 2025.

[14]Article 3 of the Federal Decree-Law No. 17 of 2025 includes the following transitional provision:

3. As an exception to the provisions of Article 46 of Federal Decree-Law No. 28 of 2022 referred to above, the Authority may conduct a Tax Audit or issue a Tax Assessment related to a refund application related to the Tax or credit balance submitted during the period referred to in Clause 1 of this Article [one year from 1 January 2026], provided that the Tax Audit is completed or the Tax Assessment is issued, as the case may be, within (2) two years from the date of submission of the refund application.

[15]Article 3 of the Federal Decree-Law No. 17 of 2025 includes the following transitional provision:

2. As an exception to the provisions of Clause 6 of Article 46 of the Federal Decree-Law No. 28 of 2022 referred to above, the Taxpayer may submit a Voluntary Disclosure in respect of the refund application submitted within the period referred to in Clause 1 of this Article [one year from 1 January 2026], in accordance with Clause 2 of Article 10 of the Federal Decree-Law No. 28 of 2022 referred to above, provided that the Voluntary Disclosure is submitted within (2) two years from the date of submission of the refund application, unless the Authority has issued a decision thereon.

GTL Notes

[G14]Clause amended, effective 1 January 2026. Earlier read as "Clauses 2, 3, 6 and 7"

[G15]Clause inserted, effective 1 January 2026. Consequentially, the remaining clauses have been renumbered.

[G16]Clause amended, effective 1 January 2026. Earlier read as "Clauses 2 or 3"

[G17]Inserted, effective 1 January 2026.

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