If you filed a UAE tax return three years ago and assumed the file was closed, the rules changed under your feet. From 1 January 2026, the Federal Tax Authority (FTA) can reach back up to 15 years in certain cases, and the clock on when an audit must finish now resets if you are notified in time. The standard window is still five years, but the exceptions have teeth.
TL;DR: The FTA's standard audit window is five years from the end of your tax period. Under Federal Decree-Law No. 17 of 2025, it stretches to 15 years for tax evasion or failure to register. Keep corporate tax records for seven years and VAT records for five. Real estate records run to 15 years.
How Far Back Can the FTA Audit Your Business?
In most cases, the FTA can audit or raise an assessment for five years from the end of the relevant tax period (Federal Tax Authority, 2026). That five-year window is the default, and for a compliant business that files on time it has not changed.
The shift sits in the exceptions. Where the FTA suspects tax evasion, or where a person who should have registered never did, the limitation period now extends to 15 years (DLA Piper, 2025). For non-registration, those 15 years are counted from the date the person should have registered, not from when they eventually did.
In our experience, the businesses most exposed here are the ones that crossed the corporate tax or VAT registration threshold quietly and never acted on it. The longer that gap runs, the longer the FTA's reach.
What Federal Decree-Law No. 17 of 2025 Changed
Federal Decree-Law No. 17 of 2025 rewrote the Tax Procedures Law with effect from 1 January 2026 (uaelegislation.gov.ae, 2026). It kept the five-year baseline but added several extensions that change how long a file can stay open. If you have not yet filed, our walkthrough of your first UAE corporate tax return covers the basics that these rules now police.
The headline change is the 15-year window for evasion and non-registration. Alongside it, the law gives the FTA more room to finish what it starts and tightens the rules on voluntary disclosures and refund claims made late in the cycle. The risk of a stale file resurfacing is now tied to your registration history and the accuracy of past returns, so the records that prove both matter more than they did a year ago.
When Does the 15-Year Audit Window Apply?
The 15-year period applies in two situations: where there is tax evasion, and where a taxable person failed to register when they were required to (RVG, 2025). Neither is a routine reassessment of an honest mistake.
Tax evasion means deliberate underreporting or concealment, not an arithmetic slip you later corrected. Failure to register covers the business that passed the corporate tax or VAT threshold and stayed silent. Corporate tax applies at 9% on taxable income above AED 375,000, so a growing company can cross into the net without realising it. Our guide to UAE corporate tax sets out who is in scope and when registration becomes mandatory.
One question clients always ask is whether an honest error opens the long window. It does not. An ordinary correction stays inside the five-year frame; the 15-year reach is reserved for evasion and the unregistered.
How Long Must You Keep Your Tax Records?
Keep corporate tax records for at least seven years from the end of the tax period they relate to (Federal Tax Authority, 2025). VAT records run to five years. Both periods start at the end of the relevant tax period, not the date you filed.
Two categories run longer. Records tied to the VAT capital asset scheme can need keeping for up to ten years, and real estate records must be held for 15 years under UAE VAT law. The FTA also expects records to be readily available, with the authority able to request access within 48 hours.
| Record type | Minimum retention |
|---|---|
| Corporate tax records | 7 years |
| VAT records | 5 years |
| Capital asset scheme | 10 years |
| Real estate records | 15 years |
When we review a client's filing history, the gap is rarely the return itself. It is the supporting evidence, the contracts, invoices, and bank records that prove a figure, that goes missing first.
What Happens If the FTA Notifies an Audit Before the Deadline?
If the FTA notifies you of an audit before the five-year window closes, it now has four additional years to complete that audit (DLA Piper, 2025). A notice issued in the final months of year five can keep a file live well beyond it.
Late-stage filings extend things too. Submit a voluntary disclosure in the fifth year and the FTA can conclude its review within one year of that submission. Lodge a refund application in the fifth year and the window for that claim stretches by two years. There is a hard stop on refunds as well: the right to recover a credit balance lapses after five years, which we covered in our note on VAT refund credit expiry. No voluntary disclosure can be submitted at all once five years have passed from the end of the tax period, with a narrow exception for correcting an earlier refund claim.
The pattern is consistent. Acting at the edge of the deadline rarely closes the door quickly; more often it holds the door open.
Practical Steps to Take Before the Window Matters
Start with registration. If you suspect you crossed the corporate tax or VAT threshold and never registered, fix it now rather than waiting for the FTA to count back from the date you should have acted. The 15-year exposure only bites the unregistered and the evasive, and acting early can limit penalties, as we explained in our piece on the corporate tax penalty waiver.
Then set a retention policy that matches the longest period you are subject to, not the shortest. A business with property holdings is on the 15-year hook for those records even if its general corporate tax file is a seven-year obligation. If an audit does land, our guide on how to prepare for an FTA tax audit walks through what the authority asks for. Digital storage that survives staff changes and system migrations is worth more than a filing cabinet here.
Frequently Asked Questions
Does the 15-year audit window apply to every UAE business?
No. The default remains five years from the end of the tax period. The 15-year window applies only to tax evasion or to a person who failed to register when required. A compliant, registered business that files accurately stays inside the five-year frame.
How long do I need to keep my UAE corporate tax records?
At least seven years from the end of the relevant tax period, per the FTA. VAT records run to five years, capital asset scheme records up to ten years, and real estate records to 15 years. Records must be available to the FTA on request, generally within 48 hours.
Can the FTA audit a year that is already past the five-year limit?
Only in defined cases. If it notified you of an audit before the five-year point, it has four more years to finish. If evasion or non-registration is involved, the reach extends to 15 years. Otherwise, a closed five-year period stays closed.
What is the deadline for a voluntary disclosure under the 2026 rules?
A voluntary disclosure cannot be submitted more than five years after the end of the relevant tax period. The only exception is to correct a refund application you submitted earlier with an incorrect amount, where the FTA has not yet decided the claim.
When did these audit limitation changes take effect?
The changes sit in Federal Decree-Law No. 17 of 2025, which amended the Tax Procedures Law with effect from 1 January 2026. The record retention obligations the FTA restated in 2025 apply alongside them.
If you are unsure how far back your exposure runs, or whether a past registration gap has put you on the long window, get in touch. We can review your filing and registration history, set a record-retention policy that matches your longest obligation, and tell you plainly where you stand before the FTA does.