When do I need to file a voluntary disclosure for VAT?
If a mistake in your VAT return or refund claim means you paid less tax (or got a bigger refund) than you should have, you must tell the FTA. For errors over AED 10,000, file a Voluntary Disclosure within 20 business days of finding it; for smaller errors, just fix it in your next VAT return if you can still do so.
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The detail
Under Article 10 of the Tax Procedures Law, a Taxable Person must submit a Voluntary Disclosure where an error in a filed Tax Return, Tax Assessment or refund claim caused Payable Tax to be understated or a refund to be overstated. Article 10 of the Executive Regulation sets the mechanics: if the resulting difference exceeds AED 10,000, a Voluntary Disclosure must be filed within 20 business days of becoming aware of the error; if AED 10,000 or less, the error should instead be corrected in a not-yet-due or current Tax Return where possible, with a Voluntary Disclosure only required if no such return is available. Where an error or omission causes no change in Due Tax, correction is via Voluntary Disclosure only in the cases specified by the FTA (per FTA Decision No. 8 of 2024), otherwise via the Tax Return itself.123
What the law says
- A Taxable Person must submit a Voluntary Disclosure if a filed Tax Return, Tax Assessment, or refund application understated Payable Tax or overstated an entitled refund.1
- Where the understatement/overstatement exceeds AED 10,000, the Voluntary Disclosure must be filed within 20 business days of becoming aware of the error; AED 10,000 or less is corrected via the next available Tax Return instead, unless none is available.2
- Where there is no change in Due Tax, correction is made by Voluntary Disclosure only in cases the FTA specifies (currently set out for VAT in FTA Decision No. 8 of 2024), otherwise by amending the Tax Return.13
What it depends on
- The 20-business-day clock runs from the date the Taxable Person or Taxpayer becomes aware of the error, not from the original filing date.2
- A Voluntary Disclosure is optional (not mandatory) where the error caused an overstatement of Payable Tax or an understatement of a refund entitled.1
- For nil-tax-impact errors, the specific triggering cases are defined by FTA Decision No. 8 of 2024, not left to general discretion.3
Check before you rely on it
- Calculate the exact AED difference caused by the error to see if it exceeds the AED 10,000 threshold
- Check whether a not-yet-due Tax Return is still available to correct a sub-AED 10,000 error
- Confirm the date you actually became aware of the error to start the 20-business-day count
Sources (3) — read the official text
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Read the article
Article 10 1. If a Taxable Person becomes aware that a Tax Return submitted to the Authority or a Tax Assessment issued by the Authority is incorrect, which resulted in a calculation of Payable Tax according to the Tax Law being less than it should have been, the Taxable Person shall submit a Voluntary Disclosure. 2. If a Taxpayer becomes aware that a Tax refund application submitted to the Authority is incorrect, which resulted in the calculation of a refund amount to which he is entitled according to the Tax Law being more than it should have been, 8 Clause amended as per Federal Decree-Law No. 17 of 2025. Federal Decree-Law No. 28 of 2022 and its amendments – As published by the Ministry of Finance 8 the Taxpayer shall submit a Voluntary Disclosure. 3. If a Taxable Person becomes aware that a Tax Return submitted to the Authority or a Tax Assessment issued by the Authority is incorrect, which resulted in the calculation of Payable Tax according to the Tax Law being more than it should have been, the Taxable Person may submit a Voluntary Disclosure. 4. If a Taxpayer becomes aware that a Tax refund application submitted to the Authority is incorrect, which resulted in the calculation of a refund amount to which he is entitled according to the Tax Law being less than it should have been, the Taxpayer may submit a Voluntary Disclosure. 5. If the Taxpayer discovers an error or omission in the Tax Return submitted to the Authority, where there is no difference in the amount of Due Tax, the Taxpayer must correct such error by submitting a Voluntary Disclosure in the cases specified by the Authority, or correct such error via a Tax Return in any other case.9 6. The Executive Regulation shall set out the detailed provisions relating to submitting a Voluntary Disclosure to the Authority and the method of application of Administrative Penalties imposed prior to the Voluntary Disclosure. Title Three – Tax Procedures Chapter One – Notification
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Article 10 – Submission of Voluntary Disclosure2
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Article 10 – Submission of Voluntary Disclosure2 1. If a Taxable Person becomes aware that a Tax Return submitted to the Authority or a Tax Assessment issued to the Taxable Person by the Authority is incorrect, 2 Article amended as per Cabinet Decision No. 17 of 2026. Cabinet Decision No. 74 of 2023 and its amendments – As published by Ministry of Finance 7 resulting in a calculation of the Payable Tax according to the Tax Law being less than it should have been, the following shall apply: a. If the amount is more than (10,000) ten thousand Dirhams, the Taxable Person shall submit a Voluntary Disclosure within (20) twenty Business Days from the date when the Taxable Person became aware of the error. b. If the amount is equal to (10,000) ten thousand Dirhams or less, the Taxable Person shall do the following: 1) If the Taxable Person is obligated to submit a Tax Return to the Authority, correct the error in the Tax Return that has not become due for submission for a previous Tax Period or in the Tax Return for the Tax Period in which the error has been discovered, whichever is earlier. 2) Submit a Voluntary Disclosure within (20) twenty Business Days from the date of becoming aware of the error, in the event that there is no Tax Return through which the error can be corrected according to subparagraph 1 of this Clause. 2. If a Taxpayer becomes aware that a Tax Refund application submitted to the Authority is incorrect, resulting in a calculation of a Refund to which it is entitled according to the Tax Law being more than the correct amount, the Taxpayer shall submit a Voluntary Disclosure to the Authority within (20) twenty Business Days from the date when the Taxpayer became aware of the error, unless the error was a result of an incorrect Tax Return or Tax Assessment, in which case the following shall apply: a. If the amount is more than (10,000) ten thousand Dirhams, the Taxpayer shall submit a Voluntary Disclosure within (20) twenty Business Days from the date when the Taxpayer became aware of the error. b. If the amount is equal to (10,000) ten thousand Dirhams or less, the Taxpayer shall do the following: 1) If the Taxable Person is obligated to submit a Tax Return to the Authority, correct the error in the Tax Return that has not become due for submission for a previous Tax Period or in the Tax Return for the Tax Period in which the error has been discovered, whichever is earlier. 2) Submit a Voluntary Disclosure within (20) twenty Business Days from the Cabinet Decision No. 74 of 2023 and its amendments – As published by Ministry of Finance 8 date of becoming aware of the error, in the event that there is no Tax Return through which the error can be corrected according to subparagraph 1 of this Clause. 3. For the purposes of implementing the provisions of this Article, the Voluntary Disclosure shall be submitted in the form and manner specified by the Authority.
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Article 1 – Error or Omission in the Tax Return
Read the article
Article 1 – Error or Omission in the Tax Return If the Taxpayer discovers an error or omission in the Tax Return submitted to the Authority for the purposes of Federal Decree-Law No. 8 of 2017 referred to above, where there is no difference in the Due Tax, they shall correct such error by submitting a Voluntary Disclosure if any of the cases stated in Article 2 of this Decision occurs. Federal Tax Authority Decision No. 8 of 2024 – Unofficial translation 1
Written by AI from the FTA sources above and checked before display. Not tax advice or official FTA information - confirm with a tax adviser before you act. Full disclaimer
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