Economic Substance Regulations For Administrative Penalties

Economic Substance Regulations Appeal Guide For Administrative Penalties

The Federal Tax Authority ("FTA") has issued a user guide to assist companies in submitting appeal request related to penalty imposed under Economic Substance Regulations ("ESR").


Companies may appeal to a decision by the FTA to impose an administrative penalty on the following grounds:

  • It did not commit the violation. 
  • The administrative penalty imposed is not proportionate to the violation.
  • The administrative penalty imposed exceeds the limits under the ESR laws.


  • Imposition of penalty by the FTA
  • Submission of appeal on MOF portal:
    • Reason for appeal;
    • Supporting documents
  • Providing additional supporting documents if required by the FTA 
  • Review of appeal request by the FTA
  • Issue of final decision by the FTA


Submit for Appeal

  • 40 working days from the imposed date of the fine

Submit additional Document Request by FTA

  • 5 Working days from the date of requesting documents

Issue a Decision of the appeal

  • 40 working days from the date of meeting all requirement

Inform Licensee of the decision

  • 5 working days from the date of issuance of the decision

Final period to pay the fine

  • 40 working days from date administrative penalty is levied


  • Assistance in filling the appeal request
  • Assistance in collating the supporting documents
  • Follow-up with the FTA

Contact Us

Markus Susilo
Markus Susilo
Partner- Payroll and Indirect Tax
Michel Ruitenberg
  Partner DIFC - Indirect Taxes