English text status

English translation published by the NBR in its bilingual Regulations file (marked unofficial). The Arabic text published in the Official Gazette remains the legal reference in the event of any discrepancy.

Practical summary

The NBR may not re-examine and reassess a previously examined Tax Period unless new information, unavailable at the earlier examination and assessment, is discovered and requires reassessment.

Who should read this?

Taxable Persons whose previously examined period is reopened and audit and dispute teams.

Why does it matter?

The earlier examination has stability but is not absolutely closed. Ask whether information is genuinely new, was unavailable earlier and actually requires reassessment.

Previously examined periodNew previously unavailable informationInformation requires reassessment

Current text

The Bureau shall not examine and re- assess Net Tax which relates to a Tax Period that has been previously examined, unless new information is discovered that was not available at the time of the previous examination and assessment, and this information requires reassessment.

Test reopening

  1. 1

    Evidence earlier examination scope and outcome.

  2. 2

    Identify alleged new information precisely.

  3. 3

    Test whether it was available earlier.

  4. 4

    Link it to the period and Tax.

  5. 5

    Distinguish required reassessment from a changed view.

  6. 6

    Keep both examination records.

Connected provisions

Direct legislative link

Regulations — Article (92)

Assessment decision

Reassessment must still be issued with reasons and required contents.

Open connected Article
Direct legislative link

Law — Article (49)

Net Tax assessment

The Law creates power and this Article constrains repeat examination.

Open connected Article

Official guides and tools

Official text

VAT Executive Regulations

Article (93)

Connected Madar tools

Connected Madar tools

Audit and Assessment Centre

Identify the audit or assessment-review stage and prepare an action list and report from your answers.

Illustrative example by Madar

Invoice found after examination

A period was examined and an undisclosed sales document later appears that was unavailable and directly affects Tax. Reassessment may be triggered. Reopening merely because the same information is now viewed differently needs justification under the new-information condition.

Questions to help you apply it

  • Same period previously examined?
  • What new information?
  • Why unavailable earlier?
  • How does it require reassessment?