VIVOS UAE · Insights · 2027 Rule Changes, Episode 5
Setting up a new company in the UAE?
If you are a foreign founder planning a new mainland or free zone company, build rules like this into the set-up plan from the start. Fixing them after licensing usually takes longer than getting them right on day one.
Most of our UAE clients need a new company and a residence visa through it, so they can live in the UAE and run the business. VIVOS advises on both. See our UAE company setup advisory and UAE work visas and immigration, or read how to set up a mainland company in Dubai.
UAE Credit Balance Refund Checklist: What a Dubai Company Checks Before 31 December 2026
Before 31 December 2026, a Dubai company should list every credit balance on its Federal Tax Authority account, by tax and period. Since 1 January 2026, a balance can be refunded or used only within five years of the end of the relevant tax period. If those years have passed, file the refund request in EmaraTax by that date.
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 for Dubai companies (as of October 2026)
- Since 1 January 2026, a credit balance with the FTA 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.
- 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.
- A late request lapses: the right to claim a refund ends (Art. 38(6)).
| Tax | Where in EmaraTax | Refund form |
|---|---|---|
| VAT | VAT tab | VAT311 |
| Excise Tax | Excise Tax tab | EX311 |
| Corporate Tax | Corporate Tax refund form | CT |
Video (80 seconds): UAE Tax Credit Deadline: Claim Old Credit Balances by 31 December 2026.
What does a Dubai company check on its FTA account?
The checklist is the same on the mainland or in a free zone: it starts from what the FTA account shows.
- List every credit balance, by tax and period.
- Find the start of the five years for each (next section).
- Mark the balances whose five years have passed or end in 2026.
- File the refund request in EmaraTax by 31 December 2026. The FTA may audit or assess it, completing that within two years of submission (Art. 3(3)).
- Ask a tax adviser to confirm your own position.
Which tax period do the five years run from?
Article 38(2) of the Tax Procedures Law, 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.
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.
Which balances can still be claimed?
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”. We found no FTA page on how to ask to use a balance, so these steps are for refunds only.
Frequently asked questions
What should a Dubai company’s credit balance list show?
One line per balance: the tax, the period, and the tax period its five years run from under Article 38(2)(a) to (c). Check each line with a tax adviser.
Can a Dubai company correct a refund request after filing it?
A Voluntary Disclosure on a request filed in the window is allowed within two years of the filing date, unless the Authority has already decided on it (Article 3(2) of Decree-Law No. 17 of 2025).
What if a credit balance arises in the last 90 days of the five years?
Article 38(3) and (4) give a later route for a balance that arises after the five years or in their last 90 days: one year from arising if it came from an FTA decision, otherwise 90 days.
We run a UAE company from Singapore. What should we check?
The company’s own FTA account holds its credit balances, so the check is the same: list each by tax and period. VIVOS Corporate Services L.L.C. in Dubai files these refund requests with the FTA; VIVOS Pte. Ltd. in Singapore supports accounting and tax compliance.
Sources
- 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; portal amendments page (Arabic, previous texts).
- UAE Federal Tax Authority, Tax Refund to Registered Tax Payers and EmaraTax: Apply for a refund. All checked 19 October 2026.
Read the full guide to the UAE tax credit deadline and the rule changes tracker. Next episode (Tue 3 Nov): COMPASS C1 Salary Benchmarks 2027: Singapore Employment Pass Dates. Or talk to our team.
Reviewed by Ray Tay, VIVOS. VIVOS Corporate Services L.L.C., Commercial Licence No. 1638200, Unit 415, Churchill Executive Tower, Business Bay, Dubai · +971 56 408 7384 · contactvivos.uae@vivos.com.sg. Part of VIVOS Group with VIVOS Pte. Ltd. (Singapore, UEN 202416468C, MOM EA Licence 24S2425). Facts checked 19 October 2026. General information, not tax advice.
Video transcript
Read the full transcript of the VIVOS video “UAE Tax Credit Deadline: Claim Old Credit Balances by 31 December 2026”
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.
