Insights · 2027 Rule Changes · Episode 5: UAE Tax Credits
UAE Tax Credit Deadline: Claim Old Credit Balances by 31 December 2026
Since 1 January 2026, a UAE credit balance with the Federal Tax Authority can be refunded or used only within five years of the end of the relevant tax period (Federal Decree-Law No. 17 of 2025). If those years have passed, file the request by 31 December 2026 in EmaraTax. After that, the right to claim a refund lapses.
What most pages still say: “An FTA credit balance can stay on your account until you need it”, or “the 31 December 2026 deadline is a VAT rule.”
What’s true since 1 January 2026: Article 38 of the Tax Procedures Law gives any credit balance five years from the end of the relevant tax period, and a late claim lapses. The previous Article 38 had no time limit (official portal, Art. 38; previous texts).
The episode video first aired on 29 October 2026. For the full, regularly updated guide, see UAE VAT registration thresholds and deadlines.
Key facts (as of October 2026)
- Since 1 January 2026, a credit balance can be refunded or used only within 5 years of the end of the relevant tax period (Federal Decree-Law No. 17 of 2025).
- Where the 5 years has lapsed, a refund or use is allowed if requested within a year from 1 January 2026. The Ministry adds balances ending in 2026.
- Last day: 31 December 2026, derived from “one year from 1 January 2026”; neither text prints it.
- Any credit balance is covered, under any tax the FTA administers, not only VAT (Art. 38(1)).
- A late request lapses: the right to claim a refund ends (Art. 38(6)).
| Point | Before 1 January 2026 | Since 1 January 2026 |
|---|---|---|
| Time limit on a credit balance | None (previous Art. 38) | 5 years from the end of the relevant tax period (Arts 38(2), 9(3)) |
| Balance past 5 years, or ending in 2026 | No limit applied | Refund or use if requested within a year from 1 January 2026 (Decree-Law No. 17, Art. 3(1); the Ministry adds balances ending in 2026) |
| Request not submitted in time | No limit applied | The right to claim a refund lapses (Art. 38(6)) |
Watch on YouTube: UAE Tax Credit Deadline: Claim Old Credit Balances by 31 December 2026 (80 seconds). Transcript below.
What is the last day to claim old UAE tax credits?
31 December 2026. Neither Federal Decree-Law No. 17 of 2025 nor the Ministry of Finance’s announcement prints that date. It is derived from “one year from 1 January 2026”, the period both give for balances past the five-year limit.
What changed on 1 January 2026?
Federal Decree-Law No. 17 of 2025, issued on 1 October 2025, amends the Tax Procedures Law (Federal Decree-Law No. 28 of 2022) from 1 January 2026 (Ministry of Finance, 29 November 2025). Article 38(2) sets the five-year limit, in the official English text as we read it:
The refund application must be submitted within 5 years from the end of the Tax Period to which (a) the excess payment was made, (b) the Tax Return or Voluntary Disclosure was submitted or the Tax Assessment issued, or (c) the credit balance arose, as the case may be.
Article 9(3) gives the use of a balance the same five years. Which of (a), (b) or (c) starts the clock depends on the balance: check your own position with a tax adviser. We give no worked example.
Is this only a VAT rule?
No. Article 38(1) covers any credit balance under any tax the FTA administers; the Decree-Law does not name VAT, Excise Tax or Corporate Tax. Many pages still say a credit can wait indefinitely, or call this a VAT rule. The first describes the previous Article 38; the second is narrower than the text.
Which balances get the transitional year?
The law and the Ministry word it differently. Article 3(1) of Decree-Law No. 17 of 2025 lets a taxpayer whose five years has lapsed apply for a refund or use the balance if requested within a year from 1 January 2026. The Ministry of Finance adds balances whose five years expires within one year of that date. We read Article 3 in the Ministry’s English text, marked “not an official translation”; the Arabic prevails.
How do you file the refund request?
In EmaraTax, open the VAT or Excise Tax tab and choose form VAT311 or EX311; for Corporate Tax, use the CT refund form. The FTA’s service card describes it as free, and VAT or Excise registrants can file one consolidated request per tax type for several periods.
The FTA may audit or assess a request filed in this window, completing it within two years of submission (Art. 3(3)). A Voluntary Disclosure on it is allowed within two years of filing unless the Authority has already decided (Art. 3(2)). The law also lets a taxpayer use a balance, but we found no FTA page on how to ask, so these steps are for refunds only.
What happens if you miss it?
If the refund application is not submitted within the deadlines in Article 38, the right to claim a refund lapses (Art. 38(6)). We found no extension on 19 October 2026; that is absence of evidence, so check again before you rely on it.
Run a UAE company from Singapore? Check it too.
The credit balances sit on the UAE company’s own FTA account, so the check is the same wherever its owner is based. Ask whoever files for it for the list, by tax and period. This is a practical prompt, not a Singapore tax point; see our Singapore and Dubai company guide.
What to do before 31 December 2026
- List every credit balance on the FTA account, by tax and period.
- Find the start of the five years for each, under Article 38(2)(a) to (c).
- Mark the balances whose five years have passed or end in 2026.
- File the refund request in EmaraTax (VAT311, EX311 or CT) by 31 December 2026.
- Ask a tax adviser to confirm your own position.
How does VIVOS help?
VIVOS Corporate Services L.L.C. in Dubai files these refund requests with the FTA, and VIVOS Pte. Ltd. in Singapore supports accounting and tax compliance.
Part of the 2027 Rule Changes series
Episode 5 of 2027 Rule Changes: What Most Pages Still Get Wrong. Every dated change is on the 2026-2027 Rule Changes Tracker. Previous episode: Malaysia Employment Pass 2027. More UAE: e-invoicing deadline and Small Business Relief to 2029. For Dubai companies: the credit balance refund checklist. Next episode (Tue 3 Nov): COMPASS C1 Salary Benchmarks 2027: Singapore Employment Pass Dates.
Video transcript
Video transcript
What is the last day to claim old UAE tax credits? The thirty-first of December 2026. Since the first of January 2026, credit balances with the Federal Tax Authority have a five-year limit, with one transitional year to file.
I’m Ray Tay, co-founder of VIVOS. Many pages still say a credit can wait indefinitely, or call this a VAT rule. The text covers any credit balance, and a late claim lapses.
The five years run from the end of the relevant tax period. For balances past that point, the law allows a refund or use if requested within a year of the first of January 2026. The Ministry adds balances ending in 2026.
Filing is what really counts. Submit the refund request in EmaraTax, on the VAT, excise or corporate tax form. The FTA may audit refunds filed in this window, for up to two years.
Miss it, then the right to claim a refund lapses. List every credit balance on your FTA account, by tax and period. Run a UAE company from Singapore? Check it too.
VIVOS Corporate Services in Dubai files these refund requests with the FTA. VIVOS in Singapore supports accounting and tax compliance. Most firms compare countries. VIVOS connects them.
Presented by an AI-generated avatar and voice of Ray Tay, co-founder of VIVOS, with AI-generated motion graphics. Written and fact-checked by VIVOS; facts checked 19 October 2026. General information, not tax advice.
Frequently asked questions
What is the last day to claim old UAE tax credits?
31 December 2026, derived from the rule that a request for a balance past its five years must be submitted within a year from 1 January 2026. Neither the Decree-Law nor the Ministry of Finance prints the date.
Is there a time limit on UAE VAT refunds?
Yes, since 1 January 2026. Article 38(2) of the Tax Procedures Law requires a refund application within five years from the end of the relevant tax period. The previous Article 38 had no time limit.
Does the five-year limit apply to Excise Tax and Corporate Tax, or only VAT?
It covers any credit balance under any tax the Federal Tax Authority administers; the Decree-Law does not name VAT, Excise Tax or Corporate Tax. The FTA’s refund forms are VAT311, EX311 and CT.
What happens to a credit balance after five years?
If the refund application is not submitted within the deadlines in Article 38, the right to claim a refund of the credit balance lapses (Art. 38(6)). For balances already past five years, the window is a year from 1 January 2026.
How do I submit a refund request in EmaraTax (VAT311, EX311, CT)?
In EmaraTax, open the VAT or Excise Tax tab and choose form VAT311 or EX311; for Corporate Tax, use the CT refund form. Complete it and submit. It is free, and VAT or Excise registrants can file one consolidated request per tax type for several periods.
Can the FTA audit a refund request filed in the transitional year?
Yes. Under Article 3(3) of Decree-Law No. 17 of 2025, the FTA may audit or assess a request filed in the window, completing it within two years of submission.
Has the 31 December 2026 deadline been extended?
We found no extension when we checked on 19 October 2026: no FTA notice, nothing on mof.gov.ae or tax.gov.ae, and no FTA FAQ or Public Clarification on the five-year rule. That is absence of evidence, so check again before relying on it.
Sources and how this guide was verified
- UAE Ministry of Finance, announcement on the Tax Procedures Law amendments (29 November 2025).
- Federal Decree-Law No. 28 of 2022 as amended by No. 17 of 2025: consolidated text (Ministry of Finance); official portal, English (Art. 38); portal amendments page (Arabic, previous texts).
- UAE Federal Tax Authority, Tax Refund to Registered Tax Payers and EmaraTax: Apply for a refund.
- Extension check: FTA announcements and the Ministry of Finance legislation list.
- All sources checked 19 October 2026.
Related services and insights
- Accounting and tax in the UAE
- Videos: UAE e-invoicing deadline · UAE Small Business Relief to 2029 · Malaysia Employment Pass 2027
Holding old credit balances with the FTA?
Send us your list of credit balances by tax and period, and we will check it against the five-year rule. Talk to our team or WhatsApp +65 8827 7870.
VIVOS Group: four licensed companies, plus teams in China and India. This topic is served by the first two.
- VIVOS Pte. Ltd. (Singapore): UEN 202416468C · ACRA Registered Filing Agent FA20240323 · MOM EA Licence 24S2425 · 14B Stanley Street, Singapore 068733
- VIVOS Corporate Services L.L.C. (Dubai, UAE): Commercial Licence No. 1638200 · Unit 415, Churchill Executive Tower, Business Bay, Dubai · +971 56 408 7384 · contactvivos.uae@vivos.com.sg
- VIVOS (M) Sdn. Bhd. (Malaysia): Registration No. 202501057568 (1658974-A)
- VIVOS Corporate Services (HK) Ltd. (Hong Kong): Business Registration No. 80545137
Reviewed by Ray Tay, VIVOS. Facts checked 19 October 2026. General information, not tax advice: your position depends on your facts.
