The revised guidance incorporates new provisions and clarifies procedures for submitting clarification requests, including those related to Pillar Two rules
The UAE Federal Tax Authority (FTA) released an updated version of its tax procedures guide on Private Clarifications (TPGPC1) on 25 July 2025. This updated guidance supersedes the version published in November 2024 and outlines the process and conditions for submitting clarification requests to the FTA.
This document provides guidance on the nature of a Clarification, who is eligible to apply for one, the circumstances under which a Clarification will not be provided or may be rejected, and details of the Clarification process. It also outlines the required documents, applicable fees, and the situations in which those fees may be refunded.
The revised TPGPC1 guide provides detailed instructions on the nature of a tax clarification, who is eligible to request one, and scenarios in which a clarification request will either not be accepted or may be rejected. It also outlines the clarification application process, including necessary documentation, applicable fees, and the conditions under which fees may be refunded.
Key changes introduced in the July 2025 version include the incorporation of provisions from FTA Decision No. 2 of 2025, which sets out the FTA’s policy on issuing clarifications and directives. The guide now also includes expanded information on submitting clarification requests related to Pillar Two rules under the OECD’s Global Anti-Base Erosion (GloBE) framework.
Further updates address the timeframes within which clarifications will be issued, as well as revisions to the grounds for rejecting applications. These revisions now clearly differentiate between situations where a clarification request will be rejected and those where it may be rejected at the FTA’s discretion.
The updated guide aims to provide greater clarity and procedural transparency for taxpayers seeking binding guidance from the FTA.
