Penalties & Disputes
Responding to Field Audit Findings
Field audit findings your options across the uae dispute ladder: review, reconsideration, tdrc objection and court appeal.
field audit fta
A field audit puts the auditor in your premises — findings carry the weight of observed facts, and the cooperation record matters as much as the documents. Cooperate fully and document everything: who attended, what was asked, what was provided, what was observed. Rebut findings with the operational records — stock logs, timesheets, process documentation. The AED 20,000 facilitation penalty punishes obstruction; the cooperation trail prevents it.
Basis: Federal Tax Authority, as published by the Ministry of Finance
- Field audit
- Findings carry observed-fact weight
- The cooperation record matters
- Approach
- Cooperate and document everything
- Attendees, requests, items provided
- Obstruction penalty
- AED 20,000
- Facilitation penalty
# Field audit findings: the situation
A field audit puts the auditor in your premises — findings carry the weight of observed facts, and the cooperation record matters as much as the documents.
Field findings often concern physical and operational matters: stock observed vs recorded, staff functions vs claimed substance, processes vs described controls. The auditor's visit notes become evidence — ensure your team gives consistent, truthful accounts, and keep your own visit records.
# Dispute strategy
Cooperate fully and document everything: who attended, what was asked, what was provided, what was observed. Rebut findings with the operational records — stock logs, timesheets, process documentation. The AED 20,000 facilitation penalty punishes obstruction; the cooperation trail prevents it.
Watchouts
- Brief the team: truthful, consistent, documented — never improvised
- Keep parallel records of every visit and request
- Provide records promptly; delay without explanation reads as obstruction
# Procedure: which rung of the ladder
Field findings that become assessments enter the same 40-business-day dispute ladder. The visit records and correspondence form the dispute file's foundation — organized cooperation during the audit is the cheapest dispute preparation.
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 |
# Running this dispute well: practical guidance
Beyond the legal strategy, the practical running of this dispute determines its outcome. Cases are rarely lost on the law alone — they are lost on missed windows, disorganized files, and strategies never reassessed. The FTA and the Committee decide dozens of cases; the file that is complete, coherent, and on time gets the fair hearing its merits deserve. Run these disciplines from the first notification, not from the first setback. Four disciplines apply:
Control the timetable from day one
Diary every deadline the moment a notification arrives: the 40-business-day reconsideration or review window, the FTA's 40+5 business-day decision period, the 40-business-day TDRC objection window, and the 40-business-day court window. Count business days only, verify independently, and work to the 10-day mark — not the deadline. Cooperate fully and document everything: who attended, what was asked, what was provided, what was observed. Rebut findings with the operational recor...
Keep the file litigation-ready
Maintain one master file from the start: every notification with its proof, every filing reference, every payment confirmation, every decision. Organize it as the bundle you would file tomorrow — indexed, chronological, every page numbered. A dispute that is always ready to file is a dispute that never misses a window scrambling for documents.
Watch the watchouts
The risks identified above are not theoretical: Brief the team: truthful, consistent, documented — never improvised Keep parallel records of every visit and request Review them monthly while the dispute runs. New facts can change the strategy — a fresh assessment, a payment made, a deadline shifted by a holiday announcement — so reassess the plan each time the file changes, not just at the start.
Know when the economics change
Reassess proportionality at each rung: the amount at stake, the cost of the next stage, and the strength of the surviving grounds. A dispute worth running at reconsideration may not be worth running at court once the 50%-of-penalties security is factored in. Settle or seek instalments where the economics turn — persistence is a virtue only while it pays.
Document everything as you go
Write the file as it happens: a dated note for every call, every decision, every payment. Memory fades and staff change; the contemporaneous note does not. When the next rung arrives — or the FTA queries a related period years later — the documented file answers questions that an undocumented one cannot. Good records are the cheapest insurance in tax disputes. Store the file where successors can find it; a dispute file that leaves with a departing employee is a liability, not an asset.
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
Which rung of the dispute ladder fits this situation?
Start where the decision sits: assessments go to Article 28 review or Article 29 reconsideration within 40 business days; refused reconsiderations go to the TDRC within 40 business days; Committee decisions above AED 100,000 can go to court within 40 business days. Match the rung to the decision, not to your frustration level.
How long does the whole dispute take?
Reconsideration: 40 business days for the FTA to decide plus 5 to notify. TDRC: 20 business days plus 5 (extendable by 60). Court appeals run on court timetables — months, not weeks. A full-ladder dispute can span a year or more; each rung, though, has a strict filing clock measured in business days.
Can I refuse the auditor access to premises?
No — obstructing the auditor risks the AED 20,000 facilitation penalty, charged personally. Cooperate, document, and dispute the findings through the proper channels afterwards. Objection to scope is made politely and in writing, not by barring the door.