Statutory Lexicon // Entry #iod

The Statutory Limitation Period: The 7-Year Forensic Window

Lexicon Entry: Audit Timelines under Federal Decree-Law No. 28

The **Statutory Limitation Period** is the legally defined window during which the Federal Tax Authority (FTA) maintains the right to conduct a Tax Audit or issue a Tax Assessment. For the 2026 tax year, this period serves as the mandatory "Data Retention Floor" for all Juridical Persons.

The General 7-Year Rule

Under **Federal Decree-Law No. 28 on Tax Procedures**, the standard limitation period is **7 years** from the end of the relevant Tax Period. This requires taxpayers to maintain **Administrative Record Integrity** for a minimum of 84 months.

Real Estate Exception

Records related to **Real Estate Assets** carry an extended statutory retention requirement of **15 years**. This includes acquisition costs, capital improvements, and disposal documentation.

Evasion & Non-Registration

The 7-year clock **does not start** if a person fails to register for tax when required. In cases of proven **Tax Evasion**, the FTA maintains an indefinite look-back period, effectively bypassing the statute of limitations.

Suspension and Extension of the Period

The limitation period may be suspended or extended under specific 2026 administrative triggers:

  • **Active Audit:** If an audit is initiated before the 7th year expires, the window is extended for a further 4 years.
  • **Voluntary Disclosure:** Filing a disclosure in the 7th year can trigger an immediate extension to allow for forensic verification.
  • **Legal Appeals:** The clock pauses during active litigation with the Tax Disputes Resolution Committee (TDRC).
"In a 2026 forensic audit, 'I deleted the files' is a confession, not a defense. If your SHA-256 fingerprint trail is broken before the 7th year, the FTA reserves the right to apply a 'Best Judgment' assessment, often resulting in significantly higher tax liabilities."
— Arakan Statutory Intelligence Brief

Disclaimer: This lexicon entry is for informational purposes only and does not constitute legal or tax advice. Arakan Forensic recommends a formal nexus assessment for all entities under Decree-Law 47.

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