Penalties & Disputes
The Assessment Review Deadline
The 40-business-day article 28 review window know the rule, count the days correctly, and protect your position.
article 28 review deadline
You have 40 business days from notification of a tax assessment (and related penalties) to request a tax assessment review under Article 28. The review and reconsideration routes cannot run in parallel on the same assessment (Article 28(5)) — choose one. Review suits pure assessment-figure disputes (especially estimates); reconsideration suits broader decision challenges. The FTA decides the review within 40 business days and notifies within 5.
Basis: Federal Tax Authority, as published by the Ministry of Finance
- Review deadline
- 40 business days from notification
- Article 28 tax assessment review
- One route only
- Review or reconsideration, not both
- Article 28(5)
- FTA decision time
- 40 business days, notified within 5
- Federal Decree-Law No. 28 of 2022 on Tax Procedures
# The 40-business-day Article 28 review window: the rule
You have 40 business days from notification of a tax assessment (and related penalties) to request a tax assessment review under Article 28.
The review and reconsideration routes cannot run in parallel on the same assessment (Article 28(5)) — choose one. Review suits pure assessment-figure disputes (especially estimates); reconsideration suits broader decision challenges. The FTA decides the review within 40 business days and notifies within 5.
# Counting and managing it
Decide the route on advice before either clock runs out: pure figure disputes go to Article 28 review, mixed disputes to Article 29. File the chosen request within 40 business days of the assessment's notification with the reasons specified, and diary the sequel — the review decision's reconsideration — from day one.
Worked example
Assessment notified 15 February: the review window runs 40 business days from the 16th. If you instead file reconsideration on 1 March, the review door closes — the choice is irrevocable in practice, so decide on advice before filing either.
# If the deadline is missed
Missing the review window leaves reconsideration as the remaining route against the assessment decision — provided its own 40-day clock (from the relevant notification) is still open. Miss both and the assessment stands, challengeable only through payment-relief routes.
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/.
| Stage | Your deadline | Authority deadline |
|---|---|---|
| Tax assessment review (Article 28) | 40 business days from notification of the assessment | FTA decides in 40 business days, notifies in 5 |
| Reconsideration (Article 29) | 40 business days from notification of the decision | FTA decides in 40 business days, notifies in 5 |
| TDRC objection (Article 32) | 40 business days from notification of the reconsideration decision; tax must be paid in full | Committee decides in 20 business days, notifies in 5 |
| Court appeal (Article 36) | 40 business days from notification of the Committee decision; 50% of penalties secured | Court timetable applies |
# Managing the 40-business-day Article 28 review window: systems and safeguards
Deadlines are a systems problem. For the 40-business-day article 28 review window, build these safeguards — each one cheap, each one proven by the disputes that failed without it:
Prove the start date
Every deadline dispute begins with the same question: when were you notified? Screenshot the EmaraTax notification with its timestamp the day it arrives, save any email or SMS notification alongside it, and log the date in a shared diary — not a personal calendar. You have 40 business days from notification of a tax assessment (and related penalties) to request a tax assessment review under Article 28. Without proof of the start date, every computation that follows is arguable.
Count on a calendar, never in your head
Decide the route on advice before either clock runs out: pure figure disputes go to Article 28 review, mixed disputes to Article 29. File the chosen request within 40 business days of the assessment's notification with the reasons specified, and diary the sequel — the review decision's reconsideration — from day one. Have a second person verify the count independently; two people making the same arithmetic error is far rarer than one. For the worked example above — Assessment notified 15 February: the review window runs 40 business days from the 16th. If you instead file reconsiderat... — the principle is the same every time: visible, verifiable counting.
Build margin into every deadline
Set reminders at 30, 20, 10, and 3 business days before the computed deadline, and plan the substantive work — not just the filing — against the 10-day mark. Portal outages, bank processing delays, and signatory unavailability all strike on final days, and none of them extends a statutory window. A filing completed early is a filing that cannot be derailed.
Cover for absence
Every deadline needs a named owner and a named backup, with handovers that explicitly list open disputes and their computed deadlines. Deadlines do not pause for leave, resignations, or public holidays — the diary must survive the people. Review all open deadlines weekly while any window is active. When ownership changes, the outgoing owner walks the incoming owner through each open item; a handover email listing the deadlines, with the diary entries attached, takes ten minutes and prevents the most common cause of missed windows.
Sources and legal basis
Legislation and decisions3
- Federal Decree-Law No. 28 of 2022 on Tax Procedures
- Federal Decree-Law No. 17 of 2025
- Cabinet Decision No. 74 of 2023 (Executive Regulation of the Tax Procedures Law)
Authorities, systems and registers2
- Federal Tax Authority (FTA)
- EmaraTax
Terms used1
- Tax Disputes Resolution Committee (TDRC)
- Federal Decree-Law No. 28 of 2022 on Tax Procedures and its amendments, consolidated 3 December 2025Federal Tax Authority, as published by the Ministry of Finance
- Reconsideration Request service card (fee, EmaraTax path, response time; page last updated 19 August 2026)Federal Tax Authority
Rates, thresholds and deadlines change. Every figure above is linked to the authority that publishes it — if the two ever disagree, the authority is right and this page is out of date. Tell us and we will fix it.
Frequently asked questions
What if I am unsure which date the clock started?
The clock runs from notification — the EmaraTax timestamp or the delivery date — not the date printed on the letter. Screenshot portal notifications on arrival and keep delivery slips. If genuinely uncertain, file against the earliest plausible date; an early filing is never penalized, a late one always is.
What proof should I keep of meeting the deadline?
The EmaraTax submission receipt with its timestamp for filings, bank value-date confirmations for payments, and the notification screenshot proving when the clock started. Keep all three together — the notification date, the deadline computation, and the compliance proof form one exhibit.
Review or reconsideration — which deadline applies?
Both are 40 business days, but they run from different notifications and cannot both be used on the same assessment. Review runs from the assessment notification; reconsideration runs from the decision notification. Map which notifications you have received before choosing — the wrong choice wastes the only shot.