Page 82 - Focus Group
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and then 1% per day thereafter up to 3 times  Reconsideration form have not been encouraging.
            the unpaid amount                                 The  form  is  entirely  online  and  in  Arabic  and  is
                                                              not linked to VAT logins of registered Tax Persons.                                                                                                                      khaleejtimes.com
         •  Incorrect Returns filing – AED 3,000/AED 5,000    Hence, in many cases, there is simply no response,
            plus % based penalties
                                                              or the response could be after many months.
         •  Incorrect Tax Invoices – AED 5,000 per invoice    Similarly filing of appeals in the TDRC are not very
                                                              common. Also, when filing an appeal, it is required
         •  Failure to display prices inclusive of VAT – AED   to first pay all dues.
            15,000
                                                              SUMMARY
         •  Not Amending VAT Details in time – AED 5,000 or
            AED 15,000 on repetition                          Given that Taxable Persons, especially MSMEs are
                                                              faced with a scenario of big penalties with little
         •  Failure to maintain business records – AED        recourse for reduction, the old proverb ‘better safe
            10,000/50,000 as the case may be                  than sorry’ is perhaps the best course of action. In

         DEREGISTRATION                                       other words, they need to ensure whether through
                                                              professional advice or otherwise, that they comply
         The final stage of the life cycle is Deregistration.   with the Law in all respects and hence are not
        Here too, in the event of not deregistering within    subject to penalties in the first place.
        the time limit of 20 business days in the cases
        mentioned under the Law, leads to penalties of AED
        10,000.

         IS THERE A RECOURSE FOR THE PENALTIES?

         The VAT Law provides some recourse for the
        reduction of the penalties by way of filing the
        Reconsideration Form or going a step further and
        filing an appeal with the Tax Disputes Redressal
        Commission. However, results from filing of the                             CA Milan Shah



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         82   TAX JOURNAL 2020                The Institute of Chartered Accountants of India (Dubai) Chapter NPIO                                 THE NATION                                                                           the nation’s history and its glorious future.
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