Start with the reconciliation

Your accounting system may show VAT recoverable while the FTA account shows a different credit. Before preparing a refund application, explain that difference. PLS’s practical starting point is a refund working file connecting the ledger, filed VAT returns and EmaraTax movements.

This checklist concerns ordinary VAT-registered business claims. Refund eligibility remains a tax question: good bookkeeping supports the review but does not turn every recorded purchase into recoverable input VAT.

1. Create a period-by-period VAT bridge

List the opening credit, VAT payable or recoverable for each filed period, payments, assessments, offsets, approved refunds and closing balance. Match the bridge to both the VAT control account and the FTA statement. Investigate differences before treating the closing balance as the claim amount.

Separate amounts already used against tax or penalties from credits still available. Keep a clear record of any previous VAT311 applications so that the same amount is not requested twice.

Sources: FTA VATP046 — Amendments to VAT Decree-Law, September 2026.

2. Check documents against the VAT reports

The FTA identifies output/input tax reports, tax invoices and supporting documents for VAT311. Build an indexed file with a reference linking each report line to its invoice, credit note or import record. Check business use and recovery conditions, and flag restricted or mixed-use costs for tax review.

  • Reconcile sales and purchase VAT reports to the returns and general ledger.
  • Match supplier names, invoice dates and amounts; resolve duplicate or missing records.
  • Keep relevant contracts, import evidence and explanations of material adjustments.
  • Document supplier verification under the current FTA requirements.

Sources: FTA — Tax Refund to Registered Tax Payers; VAT Executive Regulation, consolidated September 2026; FTA Decision No. 13 of 2026 — Validity and integrity of supplies.

3. Age the credit balance

A carried-forward balance should retain its originating tax-period information. The 2026 rules introduced time limits, including a five-year framework and transitional provisions for qualifying older credits. Flag old balances for review now; do not reset their age when migrating software or posting an opening balance.

The tax reviewer should confirm the deadline applying to each component. A single accounting balance can contain credits with different histories and time-limit considerations.

Sources: FTA VATP046 — Amendments to VAT Decree-Law, September 2026; MoF — Tax Procedures Law amendments from 1 January 2026.

4. Prepare a controlled submission pack

Keep the final reconciliation, requested amount, supporting schedules, beneficiary details, reviewer comments and management approval together. The current FTA route for ordinary VAT refunds is EmaraTax VAT311. Eligible credits from more than one period can be included in a consolidated request.

Assign responsibility for monitoring FTA messages. A complete initial pack makes follow-up easier, but does not guarantee the refund or a particular processing time.

Sources: FTA — Apply for a refund in EmaraTax.

5. Close the loop after the decision

Reconcile approval, offsets and payment to the original request. Post the accounting entries with references to the FTA decision and bank receipt, and leave a clear explanation for any balance still outstanding. Management’s cash forecast should distinguish a pending refund request from an approved and received amount.

Preserve the working file and source records for the applicable retention period and any extensions. The April 2026 Tax Procedures amendments extend retention for relevant periods associated with certain refund claims where the FTA has not yet issued a determination. Do not destroy supporting records just because the normal retention date appears to have passed.

Sources: MoF — Tax Procedures Executive Regulation amendments from 1 April 2026.

How PLS can help

PLS Accounting can assist with ledger clean-up, reconciliations, VAT-support schedules and organising the evidence behind a refund review. Tax-agent work is arranged through Dr. Ahmad Helwani’s role with Bonnard Lawson Dubai, under an agreed engagement.

Tell us your accounting software, relevant VAT periods and the records available. We can agree the accounting scope and identify the questions that need tax review. Enquiries are welcome in English or Arabic.

Explore PLS’s accounting and bookkeeping support for the underlying records, or discuss a VAT review under the appropriate engagement.