Understanding Record Retention Laws In the UAE: A Complete Guide

Record retention is not just about alignment, but a legal requirement. The UAE has a complicated structure of record retention obligations across a range of tax and corporate laws, including the Tax Procedures Law, the Corporate Tax Law, the VAT Law, and the Commercial Companies Law. 

This complete guide outlines the records your business is required to keep, for how long, and what legal basis allows you to run an efficient, compliant, and risk-free document retention policy.

Why is Keeping Records Important?

At its simplest, record retention exists so that the Federal Tax Authority (FTA) is able to establish and verify a person’s (natural or juridical) business tax obligations, taxable income, and their compliance with registration or deregistration for tax purposes. 

Not retaining sufficient records or retaining records for too long can subject your business to 

• Regulatory penalties 
• Audit complications 
• Operational inefficiencies due to data overload 
• Statutory Record Retention Requirements

1.  The Tax Procedures Law (TPL)

The records that should be maintained include:

–  Accounting records

–  Commercial books

–  Tax-related information

–  Payment and receipt documentation

–  Sales, purchases, income, and expenditure documentation

–  Balance sheets and profit/loss accounts

The period of retention will be:

–  Five years from the relevant tax year

–  +4 years where there is a tax dispute or review

Legal reference: Article 4 of TPL; Article 2 of Executive Regulations to TPL. 

2.  The Corporate Tax Law (CT Law)

Records which should be maintained:

–  Tax returns

–  Financial statements

–  Documentation in support of income, expenditure and profit

–  Excluded person documentation

The period of retention will be:

–  Seven years from the end of the tax period.

Legal reference: Article 56

In addition, for Transfer Pricing:

Records which should be maintained:

–  Master file and local file

–  Documentation concerning transactions with related and connected parties

Retention period:

–  Seven years

Legal reference: Article 55

3.  The VAT Law & Executive Regulations

Records which should be maintained:

–  Tax invoices and credit notes (issued and received)

–  Documentation regarding supplies and imports

–  Documentation regarding capital assets

–  Documentation regarding adjustments and/or corrections

–  Documentation regarding real estate transactions

–  Documentation regarding transactions broken down by Emirates

–  Documentation regarding e-commerce sales

Retention Periods:  

• Standard VAT Records: 5 years + 4 years (if under audit/dispute)  
• Capital Assets Scheme: 10 years  
• Real Estate Records: 15 years  
• Electronic Commerce (over AED 100M): 18–24 months (depending on when exceeded threshold)  

Legal References: 

• VAT Law: Articles 60, 78  
• ER to VAT Law: Articles 71, 72  

4. Under the Commercial Companies Law, Required Records: 

• Shareholder and partner registers  
• Memorandum of Association and amendments  
• Records of capital contributions  
• Annual financial statements and reports  
• Minutes of meetings/internal resolutions  
• Retention Period: Until liquidation of the company, or as agreed in the company’s memorandum  
• Legal Reference: Article 44  

Summary of Maximum Retention Periods 

Here’s a short list of the maximum required periods for different types of business records in the UAE:  

• Accounting Records, Tax Data: 7 years + 4 years (TPL, CT Law)  
• Tax Returns and Financial Statements: 7 years (Corporate Tax Law)  
• VAT Records (Invoices, Imports, Supplies): 7 years + 4 years (VAT Law)  
• Capital Assets Records: 10 years (VAT Law)  
• Real Estate Related Records: 15 years (ER to VAT Law)  
• E-commerce supply records (over AED 100M threshold): 18 months (if threshold exceeded before Dec 31, 2022)  
• 24 months after Dec 31, 2022 (if threshold exceeded after)  
• Company registers and internal documents: Until liquidation (Companies Law)  
• Transfer Pricing Documentation: 7 years (Corporate Tax Law)  

Statute of Limitations: Familiarize Yourself with the Timing

Article 46 of the Tax Procedures Law specifies the period of time that FTA can take action: 

• Standard Limitation: 5 years from the end of the relevant tax period
• If a Tax Audit has been Notified within 5 years: Your audit has an additional 4 years to be completed.  
• If you voluntarily disclose in the 5th year, An additional year.   
• In cases of Tax Evasion or failure to register, Up to 15 years.

Best Practices for Record Retention 

Proper bookkeeping is the foundation of record retention compliance. Businesses that outsource or maintain dedicated bookkeeping services in the UAE benefit from systematic record management, timely updates. The law permits either digital or hard copies, with the following conditions: 

• You may either retain the original or provide digital/photocopies of documents, but:  
• Your records must be identical to your originals  
• It must be readable and reproducible
• It must be available upon request by the FTA  
• The FTA can also impose any rules about formats and/or accessibility as needed.  

Compliance Checklist for Businesses in the UAE 

To ensure that your business is compliant, cross off the following: 

• Keep complete accounting and tax records for a minimum of 7 years.  
• Keep capital assets records for 10 years.  
• Keep documentation relating to real estate for 15 years.   
• Keep transfer pricing documentation for 7 years.  
• For e-commerce businesses exceeding AED 100M revenue, keep Emirate-level sales data for 18-24 months.  
• Retain your company registers and MoA until liquidation.  
• Maintain an easily-accessible, secure system for storing digital records. 

Statutory References

For tax practitioners, legal professionals, or compliance practitioners seeking statutory references:

• Tax Procedures Law (Federal Decree-Law No. 28 of 2022)
• Corporate Tax Law (Federal Decree-Law No. 47 of 2022)
• VAT Law (Federal Decree-Law No. 8 of 2017 & amendments)
• Executive Regulations to VAT and TPL
• Commercial Companies Law (Federal Decree-Law No. 32 of 2021)

Final Thoughts: Customize Your Retention Turn

Record retention in the UAE is not universally applicable; different laws require different lengths of time as records must be maintained, and the best course of action is to keep your retention policies aligned to the longest reviewed period, especially if there are multiple laws that apply to the same document.

Doing so will:

• Comply with the law

• Streamline disclosures, audits, etc.

• Eliminate clutter and costs of storage

• Weaken your risk to regulation or institutions

If in doubt, you should consult a reliable accounting firm in Dubai and the UAE, to audit your record retention policy.