Old UAE VAT Refunds Expire on 31 December 2026: Claim Yours Before They Are Gone
Many UAE businesses carry an excess VAT credit from earlier years. Some left it on the return to offset future tax. Others meant to claim it and never did. From 1 January 2026, that credit has an expiry date.
The UAE now limits refunds and carried-forward input tax to five years from the end of the tax period. For older credits, a transitional rule gives one last chance. It closes on 31 December 2026. After that date, the right to the money is lost permanently.
This guide explains the rule, which periods it catches, and how to claim in the seven weeks that are left.
Key takeaways
Federal Decree-Laws No. 16 and No. 17 of 2025 amended the VAT Law and the Tax Procedures Law from 1 January 2026.
Excess input tax can now be carried forward, offset or refunded for five years from the end of the tax period in which it arose. After that, it cannot be used at all.
If your five years had already run out, or run out during 2026, you can still claim, but only until 31 December 2026.
In practice this catches credits from tax periods that ended on or before 31 December 2021.
A refund claimed under this rule can be audited later, so your invoices and reconciliations need to be in order before you file.
Contents
The new five-year rule
Two laws changed on 1 January 2026. Federal Decree-Law No. 16 of 2025 amended the VAT Law (Federal Decree-Law No. 8 of 2017). Federal Decree-Law No. 17 of 2025 amended the Tax Procedures Law (Federal Decree-Law No. 28 of 2022). Both were issued on 25 November 2025.
Article 74(3) of the amended VAT Law sets the limit. Excess input tax can be carried forward for five years from the end of the tax period in which it arose. After five years, the credit cannot be used, offset or claimed as a refund.
The Tax Procedures Law now matches this. A refund request for a credit balance must be made within five years of the relevant tax period. Before 2026 there was no such limit, which is why many businesses left old credits sitting in their EmaraTax account.
There are two narrow exceptions. If a credit balance arises from an FTA decision after the five years, or in the last 90 days of them, you get one year from the date the balance arose to claim it. Other credits that arise in that late window get 90 days. Neither exception helps with an old credit you simply forgot to claim.
The transitional window that ends on 31 December 2026
A strict five-year rule would have wiped out every credit from 2018 to 2020 on day one. So Article 3 of Federal Decree-Law No. 17 of 2025 adds a transitional rule.
It covers taxpayers whose five-year period has already expired, or will expire within one year of 1 January 2026. Those taxpayers can still ask for a refund, or use the balance against tax due or penalties. The request must be made within one year of 1 January 2026, which means by 31 December 2026.
Miss that date and the refund right is gone for good. There is no further grace period in the law.
Which credits are at risk
The test is the date your five years end, not the year printed on the return. Count five years from the last day of the tax period that produced the credit.
Tax period ended | Five years end | Last date to claim |
|---|---|---|
31 March 2019 | 31 March 2024 | 31 December 2026 (transitional rule) |
31 December 2020 | 31 December 2025 | 31 December 2026 (transitional rule) |
30 June 2021 | 30 June 2026 | 31 December 2026 (transitional rule) |
31 December 2021 | 31 December 2026 | 31 December 2026 |
31 March 2022 | 31 March 2027 | 31 March 2027 (normal five-year rule) |
Several published guides describe the deadline as covering "2018 to 2020". That is a fair shorthand, but it is not complete. A credit from a tax period that ended during 2021 also reaches its five-year limit during 2026. Check each period by its end date.
What the FTA can do after you claim
A refund claimed now is not the end of the matter. The amendments give both sides extra time on these older claims.
You can still correct it. For a refund requested under the transitional rule, you may file a voluntary disclosure within two years of the request, unless the FTA has already issued its decision.
The FTA can still audit it. The FTA may audit, or issue an assessment on, these refund requests even after the normal limitation period has passed.
A late claim extends the audit window. A refund claimed in the fifth year gives the FTA two more years, from the date of the claim, to audit you.
The FTA is also stricter about input tax than it was in 2019. From 2026, input tax can be denied if the supply was part of a chain linked to tax evasion and you knew, or should have known, about it. FTA Decision No. 13 of 2026 added supplier verification steps from 1 October 2026. An old claim with weak paperwork is exactly what a reviewer will test first.
How to claim before the deadline
List every open credit. Pull your VAT return history from EmaraTax and note each period that ended with excess refundable tax.
Date each one. Add five years to the end of each period. Anything that ends on or before 31 December 2026 must be claimed this year.
Reconcile the figure. Match the credit to your VAT control account and your general ledger. A refund that does not reconcile will stall.
Collect the evidence. You need valid tax invoices, import and customs documents, and proof of payment for the input tax you are claiming.
Decide: refund or offset. You can ask for cash back, or use the balance against tax due or penalties. Offsetting can be faster where you have a liability anyway.
Check your bank details. Make sure the bank account on your EmaraTax profile is correct and validated before you submit.
Submit the refund request in EmaraTax. Do it well before mid-December. The FTA portal and your adviser will both be busy in the last two weeks of the year.
A worked example
The figures here are an illustration, not a real client.
A Dubai trading company files quarterly VAT returns. Its returns for 2019, 2020 and 2021 each ended with excess input tax, because it imported heavily in those years. It carried the credits forward, intending to use them later. Its EmaraTax balance shows AED 84,000.
Under the new rule, every one of those credits reaches its five-year limit by 31 December 2026. If the company does nothing, the full AED 84,000 is lost on 1 January 2027. If it files a reconciled refund request in November, it keeps the right to the money. It should also expect questions, and keep its import documents ready for two more years.
How GTAG can help
Gulf Tax Accounting Group reviews old VAT positions, reconciles credit balances to the ledger and prepares refund requests that hold up under review. If you think you have an old credit, talk to us now, while there is still time to claim it.
Frequently asked questions
What is the deadline for old UAE VAT refunds?
31 December 2026. Credits whose five-year period had expired, or expires during 2026, must be claimed by then under the transitional rule in Federal Decree-Law No. 17 of 2025.
Does the deadline only apply to 2018 to 2020?
No. The test is whether the five years from the end of the tax period have run out, or run out within 2026. That also includes tax periods that ended during 2021.
Can I use an old credit against tax I owe instead of asking for cash?
Yes. Under the transitional rule you can request a refund or apply the balance to tax due or penalties. Either way, the request must be made by 31 December 2026.
What happens if I miss 31 December 2026?
The refund right expires permanently. The credit cannot be refunded, offset or carried forward after that date.
Will the FTA audit an old refund claim?
It can. The amendments let the FTA audit or assess refunds claimed under the transitional rule beyond the normal time limit, and a claim in the fifth year extends its audit window by two years.
Does the five-year rule apply to new credits too?
Yes. From 2026 every excess input tax credit must be used or claimed within five years of the end of the tax period in which it arose.
About the author
Bill Anderson, FCCA is a Partner at Gulf Tax Accounting Group and Managing Partner at Business Improvement Group. He was previously Global CFO, Head of Finance and MI Operations, at the Royal Bank of Scotland corporate banking division, where he led global operations spanning over 2 billion pounds in profits and 103 billion pounds in total assets. He is a former board member of the Irish Business Council in Dubai and brings 25 years of experience across finance, strategy, audit, corporate governance and compliance.
Official sources
Middle East Tax Alert: Significant Amendments to UAE VAT Law and Tax Procedures Law, Alvarez & Marsal, 2 December 2025
These are the tax changes coming up in the UAE in 2026, The National
Federal Tax Authority announcements, Federal Tax Authority
This article is general information, not tax advice on your circumstances. The position is stated as at 10 November 2026. The Arabic text of UAE legislation prevails.
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