UAE VAT - 5-year credit expiry
Your clients' 2018-2021 VAT credits expire on 31 December.
Refund balances sitting at the FTA are forfeited permanently unless a VAT311 refund application is filed in time. We build the evidence packs white-label, at a fixed price, in five business days - your firm reviews, signs, files, and bills the recovery.
The mechanic
Found money, with a hard date.
Businesses whose input VAT exceeded their output VAT - exporters, capex-heavy years, businesses that later shrank - have carried credit balances at the FTA for years. The law changed.
Credits now expire
Federal Decree-Laws 16 and 17 of 2025 (effective 1 January 2026) cap credit carry-forward at five years from the period the credit arose.
One transitional window
Credits from 2018-2021 whose five-year window has already expired, or expires during 2026, get one grace period: a refund application filed by 31 December 2026 - or the balance is forfeited.
Only the filing must be in
The deadline applies to the application, not the payout. The FTA's standard review is 20 business days - but December filings leave no room for queries. The clock favours firms that move now.
Basis: Art. 74(3) VAT law as amended by FDL 16/2025; Art. 38 and transitional Art. 3, FDL 17/2025. Citation appendix included in every pack.
The deliverable
A review-ready evidence pack, under your brand.
- Claim summaryEntity, periods, balance derivation, claimed amount - one page your reviewer starts from.
- Invoice scheduleEvery source document scheduled: supplier, TRN, dates, amounts, status - including Arabic-language invoices, with working translations.
- Reconciliation memoThe claim tied to the filed returns, period by period, exact to the fils. The strongest audit defence a refund file can carry.
- Judgment flagsEvery point that needs professional judgment - isolated, cited to the rule, quantified, framed as options. We flag; your firm decides.
- Filing checklistWhat remains for your firm: roughly 45 minutes of review and decisions, then filing from the client's own EmaraTax account under your supervision.
Credit note received, input tax never adjusted - AED 900.00
CN-1902-007 (Feb 2019) was never reflected in any filed return; the balance is overstated by this amount. Recipients must reduce input tax in the period a tax credit note is received (Art. 63(2), VAT Decree-Law).
Every flag reads like this: finding, rule, exposure, your options.
How it works
Three steps. Zero process change for your firm.
Send the records
Ledger export and invoice files, through your systems or a shared drive. NDA first; access ends at delivery.
Five business days
Extraction, matching, reconciliation and flagging - automated pipeline, human-reviewed, maker-checker on every pack.
Review, sign, file, bill
Your firm decides every flagged point, signs, files, and bills its client for the recovery work.
Pricing
Fixed prices. No retainers, no minimums.
| Pack | Scope | Price |
|---|---|---|
| Simple | Single period, under 50 invoices, clean recordsTypical small-balance claim | AED 1,500 |
| Standard | Multi-period reconciliation, under 200 invoicesThe common 2018-2021 archaeology case | AED 2,500 |
| Complex | Record reconstruction, export and customs evidenceZero-rated exporters, missing-records cases | AED 4,000 |
Firms typically bill the same engagement at AED 5,000-15,000 or a recovery percentage. The margin - and the client relationship - are yours.