On this page
- What a VAT Refund Is and Who Can Claim One
- Carry It Forward or Claim It Back
- What Changed on 1 January 2026
- Refund Time Limits at a Glance
- How to Apply on EmaraTax
- Documents to Have Ready
- How Long the FTA Takes
- Why Refunds Get Rejected or Delayed
- Other VAT Refund Schemes
- Common Mistakes
- Frequently Asked Questions
What a VAT Refund Is and Who Can Claim One
If the input tax you can recover in a VAT return is more than the output tax you charged, the difference is excess recoverable tax. Under Article 74 of Federal Decree-Law No. 8 of 2017 on VAT, it sits as a credit in your Federal Tax Authority (FTA) account and is used against VAT or administrative penalties you owe in later periods.
Whatever is left can be paid out, but only if you ask for it with a refund request, form VAT311, on EmaraTax. Nothing is refunded automatically. The businesses that end up in credit are typically exporters and others with mostly zero-rated sales, companies in a start-up or fit-out phase, and anyone who bought a large asset in a single quarter.
Since 1 January 2026 a credit that is not refunded or used within five years from the end of the tax period in which it arose is lost.
Carry It Forward or Claim It Back
Leaving the credit in your account costs nothing, and it is used up as soon as your returns show VAT payable. That is usually the sensible choice when the credit comes from a one-off purchase and you expect normal output tax in the next quarter or two.
A refund makes more sense when you are structurally in credit, such as an exporter that will never generate enough output tax to absorb its input tax, or when the amount matters for cash flow. Bear in mind that the FTA can allocate a credit balance to other tax or amounts you owe it under Article 9 of the Tax Procedures Law.
And a refund request is reviewed, and can be referred to audit, so only claim what your records support.
What Changed on 1 January 2026
Until the end of 2025, a VAT credit had no statutory expiry. Federal Decree-Law No. 16 of 2025 amended Article 74 so that excess recoverable tax can be carried forward for no more than five years from the end of the tax period in which it arose.
If no refund is requested and the credit is not used within that period, the right to it lapses. Federal Decree-Law No. 17 of 2025 set the matching rule for refund requests in Article 38 of the Tax Procedures Law, with two narrower windows for credits that arise late.
A credit resulting from an FTA decision issued in the last 90 days of the five years, or after they end, can be claimed within one year of arising. Other late credits get 90 days. The FTA also has two years from the request date to audit a refund claimed in the fifth year or under those late windows.
Important
Older Credits: Claim by 31 December 2026
A transitional rule in Federal Decree-Law No. 17 of 2025 protects older balances. If the five-year period for a credit expired before 1 January 2026, or expires within one year of that date, you can still request a refund provided you do so within one year from 1 January 2026, which means by 31 December 2026. The Ministry of Finance has not listed the tax periods this covers and advisers' commentaries differ, so if your balance includes credits from the early years of VAT, claim them before that date rather than rely on your own cut-off calculation. Credits outside the rule expire on the normal five-year basis.
Refund Time Limits at a Glance
| Normal limit | Five years from the end of the tax period in which the credit arose |
|---|---|
| Credits whose five years ended before 2026 or end during 2026: request by 31 December 2026 | |
| Credit created by an FTA decision issued late in, or after, the five years: one year from the date it arises | |
| Other credits that arise late | 90 days from the date they arise |
| FTA decision under the law | 20 business days from submission, or longer if the FTA notifies you |
| FTA published service time | 25 business days for a complete application, 55 working days if referred to audit |
| Payment after approval | The FTA starts the refund within 5 business days of notifying you |
| Service fee | None |
How to Apply on EmaraTax
- 1
Bring your filings up to date
File every VAT return that is due. Under Article 26 of the Tax Procedures Executive Regulation, the FTA can hold back a refund until overdue returns are in. Reconcile the credit shown in EmaraTax with your VAT control account and correct any return errors first.
- 2
Open form VAT311
Log in to EmaraTax with UAE Pass, go to the VAT tab on your dashboard and select VAT311. One request can cover eligible credit balances from several tax periods.
- 3
Enter the amount and your bank details
EmaraTax validates UAE beneficiary account details automatically before it pays, so use an account in the business's own name and enter the IBAN exactly as it appears on your bank's IBAN letter.
- 4
Upload the supporting documents
The FTA lists an output and input tax report, plus the tax invoices and supporting documents behind the claim. Attach them with the request. If the application is incomplete, the FTA asks for more and may take a further 25 business days after you resubmit.
- 5
Track the request and answer queries
Status updates and FTA questions appear in your EmaraTax account. Reply fully and quickly. If the claim goes to audit, the FTA's 55-working-day estimate only starts once you have provided everything requested.
Documents to Have Ready
- Output and input tax report for the periods covered by the claim
- Tax invoices for the input tax claimed, starting with the largest purchases
- Customs declarations and import documents for imported goods
- Export evidence for zero-rated exports, such as the customs declaration plus a bill of lading or air waybill (Article 30 of the VAT Executive Regulation)
- Proof that suppliers have been paid
- A recent IBAN letter from your bank
- Your apportionment calculation if you also make exempt supplies
- Records of supplier and transaction checks for input tax claimed from 1 October 2026
How Long the FTA Takes
The legal timetable is in Article 26 of Cabinet Decision No. 74 of 2023, the Tax Procedures Executive Regulation, and the April 2026 amendments left it unchanged. The FTA must decide within 20 business days of submission, or within a longer period if it notifies you, and must start paying within five business days of notifying you of approval.
The FTA's own service page, updated in August 2026, quotes 25 business days for a complete application and 55 working days where audit needs to investigate, counted from when you provide everything requested. While a request is pending, you must also keep the records for the periods it covers for two years beyond the normal retention period.
Why Refunds Get Rejected or Delayed
- No valid tax invoice, or an invoice missing required details. Article 55 of the VAT Law allows recovery only once you hold the invoice, or the import documents for imports.
- Suppliers not paid. The Executive Regulation treats the consideration as paid only if you intend to pay within six months of the agreed date.
- Blocked input tax. Article 53 of the Executive Regulation blocks VAT on entertainment for anyone other than employees (customers, officials, shareholders) and on motor vehicles available for anyone's personal use.
- Staff benefits that no longer qualify. From 1 October 2026, Cabinet Decision No. 149 of 2026 limits recovery on benefits given under a contract or policy to the cases in FTA Decision No. 17 of 2026.
- Input tax relating to exempt supplies or non-business activity, or a weak apportionment calculation.
- Purchases linked to tax evasion. New Article 54 bis lets the FTA refuse input tax where you knew, or should have known, of the link. Skipping the supplier and transaction checks set by FTA Decision No. 13 of 2026 from 1 October 2026 counts as 'should have known'.
- Cash payments. Cabinet Decision No. 149 of 2026 blocks input tax on cash-paid supplies above a value to be set by the Minister of Finance, so check whether that decision has been issued and covers your periods.
- Figures that do not reconcile across the claim, the returns, the tax report, your ledger and customs import data.
- Overdue returns or bank details that fail validation, which hold up payment even when the claim is sound.
Other VAT Refund Schemes
Separate refund routes exist under Article 75 of the VAT Law and related Cabinet decisions: UAE nationals building a new home, tourists, unregistered foreign businesses, foreign governments, diplomatic missions and international organisations, the construction and operation of mosques, and licensed suppliers of exhibition and conference services to overseas participants. Each has its own conditions and process.
Common Mistakes
- Leaving old credits untouched until they lapse.
- Assuming the FTA will pay out a credit on its own. You have to file VAT311.
- Applying on top of a return you know is wrong. Correct it first, normally through a voluntary disclosure.
- Ignoring an error in a refund claim. Under the Tax Procedures Executive Regulation, as amended from 1 April 2026, an error that leads to an excess refund generally needs a voluntary disclosure within 20 business days of discovery. Where it stems from a return and is AED 10,000 or less, it can usually be corrected in the next return.
- Including VAT on client entertainment or on cars staff can use privately.
- Submitting with no documents and waiting for the FTA to ask.
Frequently Asked Questions
- Do I have to claim a refund, or can I leave the credit in my account?
- You can leave it, and it will be offset against VAT you owe later. Any part not refunded or used within five years from the end of the period in which it arose lapses.
- How do I work out when my credit expires?
- Count five years from the end of the tax period that created it. For a credit from the quarter ending 31 March 2022, the five years run to 31 March 2027. If they ended before 2026 or end during 2026, you have until 31 December 2026.
- Can the FTA use my VAT credit to settle other amounts?
- Yes. Article 74 offsets it against VAT payable and administrative penalties, and Article 9 of the Tax Procedures Law lets the FTA allocate a credit balance to other tax or amounts you owe.
- Does a refund request lead to an audit?
- Not automatically, but the FTA can refer it to audit, and a request filed in the fifth year of the limit gives the FTA two years from the request date to audit it.
- Is there a fee for a VAT refund request?
- No. The FTA lists its refund service for registered taxpayers as free of charge.
Important
Before You Rely on This Guide
This guide reflects UAE VAT and Tax Procedures legislation and FTA guidance in force on 1 November 2026. Several of these rules changed during 2026 and more decisions are expected, so confirm the current position on the FTA website before you claim. It is general information, not advice on your particular circumstances.
Sitting on a VAT Credit?
Marifah Tax Advisory can reconcile your credit balance, flag amounts close to the five-year cut-off, review the input tax behind the claim and prepare the VAT311 request and supporting file. Book a free consultation to go through your position.