Tax Assessment Review Under Article 28

Article 28 is the Tax Procedures Law's dedicated assessment-review mechanism: 'a Person may submit a request to the Authority to review a Tax Assessment or part thereof and any related Administrative Penalties.' Where reconsideration challenges decisions broadly, review targets the assessment's figures specifically — making it the natural rung for estimated assessments, computation disputes, and assessments whose numbers (rather than legal character) are wrong.

This topic sits inside the UAE's four-stage dispute ladder: tax assessment review (Article 28, 40 business days), reconsideration (Article 29, 40 business days), TDRC objection (Article 32, 40 business days with the connected tax paid in full), and court appeal (Article 36, 40 business days with 50% of penalties secured). Each stage is a precondition for the next — you cannot skip a rung, and each has its own clock.

Request within 40 business days of notification of the assessment and related penalties, specifying the reasons, in the form and manner the Authority specifies (Article 28(2), (6)). The Authority reviews and issues its decision within 40 business days of receiving the request, informing you within 5 business days of issuance (Article 28(3)). Then Article 28(4): you may submit a reconsideration request under Article 29 against the review decision within 40 business days of notification — or of the expiration of the decision timeframe. The review is thus both a remedy and a gateway: it can resolve the figures, and where it does not, it feeds the reconsideration.

Review's strength is focus: the Authority re-examines the assessment's construction — the estimate's methodology, the computation's inputs, the figures' support. Lead with the side-by-side schedule (assessment vs actuals) and the methodology attack; these are review's native language. The review decision, with its stated reasoning, then becomes the reconsideration's target where needed — a two-step that gives the figures two hearings. And where the Authority lets the 40-day decision timeframe expire, Article 28(4)'s 'expiration of the timeframe' language provides the path onward without waiting indefinitely.

Every stage runs on business days — Fridays, Saturdays, Sundays and UAE public holidays do not count — and every clock starts on notification, not on the date printed on the letter. Diary the notification date the day it arrives: screenshot the EmaraTax timestamp or keep the delivery proof. File at the 10-day mark, never on the deadline; portal outages on the final day are your problem, not the FTA's.

The FTA decides reconsideration and assessment-review requests within 40 business days and notifies within 5. The TDRC decides objections within 20 business days and notifies within 5, extendable by up to 60 business days where the case needs it. Miss a filing window and the request is inadmissible — the merits are never heard, and the courts have no power to extend these statutory windows.

For assessment-figure disputes, Article 28 review is the purpose-built tool: 40 days to request, 40+5 for the decision, with reconsideration as the sequel. File it with the figures attacked precisely, diary the sequel's clock from the decision, and let the review do what it was designed for — or fail informatively, so the reconsideration knows exactly what to answer.

If the deadline is close or the amount is large, get help before you file. Call +971 58 541 4616, message us on WhatsApp at https://wa.me/971585414616, email info@taxadvisors.ae, or use the contact form at /contact/.

The patterns below recur across UAE tax disputes. Avoiding them is worth more than any single clever argument. Review this list before filing at each rung — the mistakes compound up the ladder, and a file that avoids all four starts every forum from strength: