Old VAT credit on EmaraTax? Claim the refund before 31 December 2026

Last updated 10 November 2026 · Facts checked on mof.gov.ae and tax.gov.ae on 10 November 2026

The short answer

Since 1 January 2026, a UAE business must ask for a refund of a tax credit balance within 5 years of the end of the tax period that created it. Balances whose 5 years ran out before 2026, or run out during 2026, get one last chance: the request must be filed within one year from 1 January 2026, so by 31 December 2026. After that, the law says the right to the refund lapses.

What changed on 1 January 2026

Federal Decree-Law No. 17 of 2025 amended the Tax Procedures Law (Federal Decree-Law No. 28 of 2022). The Ministry of Finance announced it on 29 November 2025 (MoF, checked 10 Nov 2026).

The Ministry also says a taxpayer can file a voluntary disclosure linked to that refund request within two years of filing it, if the FTA has not decided the request yet.

Who has a credit balance?

You may have one if any of these apply to you:

• You paid more VAT on costs than you charged on sales, so your VAT returns showed "excess recoverable tax" that you carried forward instead of asking for it back. This is common for new companies with big setup costs and for businesses that export or sell zero-rated goods and services.
• A penalty you paid was later waived, and the amount came back to EmaraTax as a credit.
• You paid tax twice by mistake, or paid before a return was corrected.

Many small companies never ask for a refund. The credit simply sits in the EmaraTax account, and owners think "we will use it later". Under the new rule, "later" has an end date.

Which tax periods are inside the 31 December 2026 window?

The Ministry's wording covers balances where the 5-year period expired before 1 January 2026, or expires within one year of that date, so during 2026 (MoF, checked 10 Nov 2026). The law's transitional rule (Article 3 of Federal Decree-Law No. 17 of 2025) lets you ask either for a refund or to use the old balance to pay tax or penalties, as long as the request is filed within the year.

The law counts the 5 years from the end of the relevant tax period, which depends on how the credit arose (Article 38(2)). The table below counts from the end of the VAT quarter the return covered. That is the earliest possible date, so it is the safe way to plan.

Credits whose 5 years end in 2027 or later are not part of the 31 December 2026 window. Their deadline is the end of their own 5 years, which comes soon for the 2022 quarters.

Not sure which period your balance comes from? EmaraTax shows the history of your account. We can read it with you (see the call at the end).

How to check your balance and ask for the refund

1. Log in to EmaraTax with the account that holds your Tax Registration Number.
2. Open your account balance / statement and look for a credit balance, and for the tax periods it comes from.
3. Match the balance to your VAT returns. The excess input VAT should agree with the returns where you carried it forward.
4. Prepare the supporting documents: purchase invoices for the big input VAT amounts, import declarations, and proof of exports or zero-rated sales.
5. Submit the refund request in EmaraTax: on the VAT tab, open form VAT311 and fill in the refund request. The FTA's service page asks for an output and input tax report plus the tax invoices and supporting documents.
6. Answer the FTA's questions quickly. The FTA says it handles a complete request in 25 business days, or 55 working days if it goes to audit, and it can ask for more documents first. The 31 December 2026 date is about filing the request, not about receiving the money.

Mistakes we see

• Waiting for "a bigger amount" before asking. The old balance may expire meanwhile.
• Bank details on EmaraTax that don't match the company's account, which delays payment.
• Filing without the invoices ready. The FTA asks, and the request stalls.

Does this affect corporate tax as well?

The new rule is in the Tax Procedures Law, which covers taxes the FTA administers, and the Ministry describes it in general terms ("credit balances"). Corporate tax only started for periods beginning on or after 1 June 2023, so no corporate tax credit can be 5 years old yet. In 2026, the urgent case is VAT, plus excise tax for the few businesses registered for it (excise has existed since 2017; its refund form is EX311).

Frequently asked questions

Is the deadline 31 December 2026 or 1 January 2027? The Ministry says "within one year from 1 January 2026". Treat 31 December 2026 as the last day, and don't leave it to the final week: 31 December 2026 is a Thursday, just before the New Year holiday.

What happens if I miss it? For balances inside the transitional window, the law says the right to the refund lapses (Article 38(6)). The balance can't be refunded or used against future tax.

My company is in a Free Zone. Does this apply? Yes, if the company is VAT-registered and has a credit balance. Free Zone status doesn't change the Tax Procedures Law.

Can I use the credit against my next VAT return instead? For old balances, the transitional rule lets you ask to use them against tax or penalties instead of a refund, but that request must also be filed by 31 December 2026. If you have little tax to pay soon, the refund request is usually the practical route.

Do I need an accountant to file the request? No, the owner can file in EmaraTax. Most delays come from missing documents, so preparation matters more than who presses "submit".

Have an old VAT credit? Let's check it before 31 December

In a free 30-minute Zoom call we look at your EmaraTax balance with you, tell you which tax periods are at risk and what documents you need. If you'd like, we prepare the refund request and send it to you for approval before anything goes to the FTA.

Book my free 30-minute call · Message us on WhatsApp: +971 52 713 7661

Also useful: VAT registration in the UAE · Accounting services in Dubai · UAE tax deadlines 2027 · Check your compliance in 2 minutes

Sources

All sources checked on 10 November 2026.

• Ministry of Finance, Ministry of Finance to implement amendments to the Tax Procedures Law starting early 2026 (29 November 2025): Federal Decree-Law No. 17 of 2025; 5-year refund limit; transitional requests within one year from 1 January 2026; voluntary disclosure within two years
• Federal Tax Authority, Federal Decree-Law No. 28 of 2022 on Tax Procedures, consolidated: Article 9(3) (using a credit within 5 years), Article 38 (5-year refund limit, lapse), Article 3 of Federal Decree-Law No. 17 of 2025 (transitional rule), as published in English by the Ministry of Finance
• Federal Tax Authority, Tax Refund to Registered Tax Payers (page updated 19 August 2026): forms VAT311 and EX311, documents needed, 25 / 55 business-day processing times
• Ministry of Finance, Federal Decree-Law No. 47 of 2022 on Corporate Tax: corporate tax applies to tax periods starting on or after 1 June 2023

Update trigger: any FTA reminder or extension of the window. After 31 December 2026, this page becomes a guide to the standard 5-year refund rule.

Next step: Accounting services in Dubai

vat refund uaeexcess input vatemaratax refundtax procedures lawcredit balancefta