Introduction
Under the UAE Corporate Tax Law and Federal Tax Authority (FTA) regulations, businesses may sometimes realize that they have made an error or omission in their tax return, refund application, or other filing. To correct such mistakes, the FTA allows taxpayers to file a Voluntary Disclosure (VD).
The Voluntary Disclosure Form is a structured document submitted through the EmaraTax portal, enabling taxpayers to rectify errors proactively and avoid harsher penalties that could arise during an FTA audit.
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When Should a Voluntary Disclosure Be Filed?
A taxpayer must file a VD form if:
1. Errors or omissions are discovered in a previously filed return or document.
2. Incorrect tax treatment was applied, such as wrong deductions or exemptions.
3. Underreporting or overreporting of income, expenses, or tax liability occurred.
4. Missed adjustments in Transfer Pricing or related-party transactions are identified.
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Key Information Required in a Voluntary Disclosure Form
A standard VD form typically requires:
1. Taxpayer Details
• Taxpayer name (legal entity)
• Tax Registration Number (TRN)
• Trade License details
• Financial year / tax period
2. Original Submission Reference
• Reference number of the original filing (return, refund, or declaration).
• Date of the original submission.
3. Details of the Error or Omission
• Type of error (e.g., income underreported, expense misclassified, deduction overstated).
• Explanation of how the error occurred.
• Supporting references (IFRS adjustments, tax law articles, etc.).
4. Corrected Figures
• Taxable income as per original filing.
• Taxable income after corrections.
• Tax liability difference (increase/decrease).
5. Supporting Documentation
• Corrected financial statements (if applicable).
• Benchmarking/TP analysis (if related-party transactions are involved).
• Any other documents evidencing the adjustment.
6. Declaration by Taxpayer
• Authorized signatory details.
• Date and signature (digital submission via EmaraTax).
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Sample Format (Illustrative Extract)
Section 1 – Taxpayer Information
• Company Name: ________________________
• TRN: _________________________________
• License No.: __________________________
• Tax Period: ___________________________
Section 2 – Reference Information
• Original Return/Submission No.: __________________
• Date of Submission: ____________________________
Section 3 – Error/Omission Details
• Nature of Error: _______________________________
• Explanation: __________________________________
• Supporting Law/Rule: ___________________________
Section 4 – Corrected Figures
• Taxable Income (Original): AED ___________
• Taxable Income (Corrected): AED __________
• Corporate Tax Payable (Original): AED ______
• Corporate Tax Payable (Corrected): AED _____
• Difference: AED __________________________
Section 5 – Declaration
I, the undersigned, declare that the information provided in this Voluntary Disclosure is true, accurate, and complete.
Name: _______________________
Designation: __________________
Signature: ____________________
Date: ________________________
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Penalty Considerations
• Filing a VD before an FTA audit notice may reduce penalties significantly.
• Penalties may apply for late corrections, but they are usually lower than audit-triggered penalties.
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Best Practices for Filing a VD in UAE
• Review corporate tax computations carefully before filing returns.
• Conduct internal audits to identify potential errors early.
• File VD forms promptly upon identifying discrepancies.
• Keep supporting documents ready for any FTA review.
• Engage professional tax advisors to ensure accuracy and reduce penalty exposure.
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Conclusion
The Voluntary Disclosure Form is an important compliance tool that allows businesses in the UAE to correct tax return errors proactively. Having a structured format for disclosure, backed by supporting documents, strengthens a company’s credibility with the FTA and minimizes penalty exposure.
By maintaining accurate tax records, performing regular reviews, and filing voluntary disclosures when needed, businesses can ensure long-term compliance and build trust with regulators.
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✍️ Prepared by Sheikh Anwar Accounting and Auditing LLC – Registered Auditor with the Ministry of Economy (Auditor Entry No. 5817, Company Entry No. LC4695-01). We specialize in Corporate Tax, VAT, Transfer Pricing, and AML Compliance, assisting businesses with Voluntary Disclosures and FTA dealings.
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