Cases of Extension of the Deadlines for Accepting the Submission of a Tax Assessment Review Request or a Request for Reconsideration

The FTA issued Decision No. 1 of 2025 (dated 17 February 2025) to clarify the circumstances under which it may grant an extension for submitting a tax assessment review or reconsideration request. This applies when a taxable person is unable to meet the specified deadline to submit the tax assessment review request or reconsideration request due to certain reasons.

Tax Assessment Review

The tax assessment review process allows individuals to request a review of their tax assessment and related administrative penalties by independent FTA officials, based on their facts and evidence, and audit procedures. This process is available if the individual believes there were technical errors in the application of tax legislation or treaties, calculation errors, or audit procedures leading to incorrect tax differences and administrative penalties. The review process ensures fair and accurate tax assessments and penalties.

It is not permitted to submit a tax assessment review request in respect of which the person already applied for reconsideration.

FTA shall issue a Tax Assessment to determine the value of the Payable Tax, Refundable Tax or any other matters specified by the Tax Law or the Executive Regulations, and shall notify the Taxpayer of the same within (10) ten Business Days from the issuance date thereof in any of the following cases:

1. The Taxable Person fails to apply for the Tax Registration within the time limit prescribed in the Tax Law.
2. Failure of the Registered Person to submit the Tax Return within the time limit prescribed by the Tax Law.
3. The Registered Person’s failure to pay the Tax indicated as a Payable Tax in the Tax Return submitted within the time limit prescribed in the Tax Law.
4. The Taxable Person has submitted an incorrect Tax Return.
5. The Registered Person’s failure to calculate the Tax on behalf of another Person when he is obliged to do the same in accordance with the Tax Law.
6. If the Payable Tax is incomplete as a result of Tax Evasion by the Person or due to Tax Evasion in which he was involved.
7. Any other cases under the Tax Law.

“If the person wishes to introduce new information or additional documentary evidence/facts that were not presented to the FTA auditors during the audit process, the tax assessment review mechanism is not the appropriate dispute channel. In such instances, the person may apply for reconsideration.”

Reconsideration request

A person may opt to forego the option to request a tax assessment review and submit a reconsideration request if the person wants to dispute the tax assessment and related administrative penalties assessment. The person may only submit a reconsideration request if that person already submitted a tax assessment review request after any of the following:

• The person received the tax assessment review decision and disagrees with the outcome, or
• The FTA did not issue a decision on the matter within the prescribed period i.e. within 40 business days from the date the person submitted the request for a tax assessment review (or a longer period where the person is notified of an extension).

As part of the reconsideration process, the person may submit additional information and documentary evidence that were not available during the tax audit.

What is the deadline for submitting the Tax Assessment Review Request or a Request for Reconsideration?

If a person wants to request a tax assessment review or request for reconsideration, the request (including reasons for the request) must be submitted to the FTA within 40 business days from the date the person is notified of the tax assessment and related administrative penalties.

As per the latest FTA decision No. 1 of 2025, FTA mentioned the cases of Extension of the Deadlines for Accepting the Submission of a Tax Assessment Review Request or a Request for Reconsideration. The following are the cases mentioned by the FTA.

What are the cases the Deadline for Tax Assessment Review or Reconsideration Can Be Extended by the FTA?

1. The occurrence of an accident or a serious illness for the authorized signatory.
2. The death of the authorized signatory, including the Legal Representative, or any of his/her family members (of first or second-degree).
3. A temporary Business disruption that is beyond the Person’s control.
4. A damage of records due to a disaster.
5. A general malfunction in the Authority’s systems.
6. A sudden discontinuation of Business or Business records due to the installation of a new computer system.
7. The Authority’s request for additional documents from the Taxpayer, provided that the Taxpayer can prove the inability to obtain such documents within the legally prescribed deadlines.
8. A force majeure to be determined at the Authority’s discretion.

When Requests for Deadline Extensions in Tax Assessment Reviews Are Rejected?

1. The Taxpayer is unaware of their obligations.
2. The delay was caused by the negligence of a third party on whom the Taxpayer relied, such as a Tax Agent or a Legal Representative.
3. A complexity in the topic of the Tax Assessment Review request or the request for Reconsideration, due to which the Taxpayer could not submit the request on time.
4. The Applicant was busy running their Business.

Implementation of the Decision

This Decision shall come into effect as of 1 March 2025.

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