When do I need to file a voluntary disclosure for VAT?

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

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.

fixed penalty listed in Clause 1 of this penalty, a penalty equal to the that Tax difference of at least 500 shall be imposed. 3. Anyone correcting their Tax Return prior to the due date of payment shall be excluded from the penalty imposed under Clauses 1 and 2 of this penalty. 11 The submittal of a Voluntary Disclosure by the Person/Taxpayer on errors in the Tax Return, Tax Assessment or refund application pursuant to Article 10(1) and 10(2) of the Tax Procedures Law. Without prejudice to the potential consequences of the penalty mentioned in Clause 10 of this Table, a percentagebased penalty shall be applied on the difference between the Tax that was calculated and that which should have been calculated, pursuant to the following: 1. 5% on the difference, where the Voluntary Disclosure is submitted within one year from the due date of submission of the Tax Return, the Tax Assessment, or the relevant refund application; 2. 10% on the difference, where the Voluntary Disclosure is submitted within the second year following the due date of submission of the Tax Return, the Tax Assessment, or the relevant refund application; 3. 20% on the difference, where the Voluntary Disclosure is submitted within the third year following the due date of submission of the Tax Return, the Tax Assessment, or the relevant refund application; 4. 30% on the difference, where the Voluntary Disclosure is submitted within the fourth year from the due date of submission of the Tax Return, the Tax Assessment, or the relevant refund application; Cabinet Decision No. 49 of 2021 - Issue Date: 28 April 2021 - Unofficial Translation 4