ZATCA Objection: The Full Appeal Path, Step by Step | Hespah LLC [Skip to main content](#main-content)[![Hespah LLC](https://centralcdn.hespah.com/home_logolight_file2png.webp)](/en)Search More [Home](/en) [Learning Hub](/en/courses) [About us](https://hespah.com/who-we-are) [Blog](/en/blog) [Contact Us](/en/contact) Login[New Account](/en/register) 1. [Home](/en) / 2. [Blog](/en/blog) / 3. ZATCA Objection: The Full Appeal Path, Step by Step ZATCA Objection: The Full Appeal Path, Step by Step =================================================== 2026-10-06 / 2 weeks ago Sixty days, counted from the day after notification, not the date printed on the decision. That window separates an assessment you can still argue from one that hardens for good. A ZATCA objection runs on deadlines before arguments. What is a ZATCA objection? -------------------------- A ZATCA objection is a grievance against a Zakat, Tax and Customs Authority decision that places a financial obligation on the taxpayer: a zakat assessment, a tax re-assessment, a penalty, a refused refund. Royal Order No. (25711) dated 8 Rabi al-Akhir 1445H governs it through four stations, each with a deadline that kills the right once it lapses. The scope runs wider than most expect. It covers zakat assessments and their amounts, and likewise penalties from ZATCA's assessment across tax types. Besides that, it reaches post-clearance customs audit, refused refund requests, and credit balances. In short, any decision that puts a number on you, or withholds one owed, can carry a ZATCA objection. ![The five statutory deadlines of a ZATCA objection, from grievance to appeal](https://centralcdn.hespah.com/uploads/emils/17913101790.jpeg "The five statutory deadlines of a ZATCA objection, from grievance to appeal") The ZATCA objection path: four stations, five deadlines ------------------------------------------------------- Article Five of the Committees work rules draws the whole line. Every deadline starts the day after notification, because the regulator chose the date of knowledge over the date of drafting. Consequently the day a decision leaves the printer counts for nothing. Station Body Deadline Basis Grievance against the decision ZATCA Objections Department 60 days from the day after notice Article Five ZATCA rules ZATCA 90 days from filing Article Five Settlement request or direct case Internal committee or circuits 30 days from refusal or the ninety lapsing Article Five Case after settlement fails First-instance circuits 30 days from the committee decision Article Five Appeal request Appeal circuits 30 days from the day after receipt Article Thirty-Four Station one: the grievance with ZATCA within sixty days ------------------------------------------------------- Most files end here, and the order leaves no choice: a ZATCA objection cannot reach the circuits before the grievance goes to ZATCA. You file through ZATCA's portal under "Objections and Reviews", entering the review reason, the guarantee data and the undertaking. ZATCA must rule within 90 days. Four outcomes exist: full acceptance in your favour, partial acceptance, full rejection, or silence until the ninety days run out. Silence opens the same door as rejection. However the next deadline counts differently, since rejection starts it from notification whereas silence starts it from the lapse. ZATCA objection conditions you must meet ---------------------------------------- ZATCA publishes three conditions on the service page, and firms stumble on the first more than the rest: 1. **Pay the undisputed amounts in full before objecting.** Contest part of the assessment? Settle the accepted part first. Article Seven backs this, since an objection does not change the duty to pay the undisputed amount. 2. **Explain the grounds.** Identify the financial periods, the disputed items, and the technical and statutory basis for each. A request that merely calls the assessment excessive goes to study, then refusal. 3. **Provide a bank guarantee or pay a cash guarantee** over the disputed amounts — a separate step in the electronic request. That third condition turns a ZATCA objection from paperwork into immediate cash. Moreover, since penalties make up the bulk of many assessments, read our [breakdown of VAT penalties](https://hespah.com/en/blog/vat-penalties-saudi-arabia) before deciding what to contest. Station two: the internal settlement committee before court ----------------------------------------------------------- After ZATCA replies — or stays silent — you hold 30 days and two routes. Firstly, ask to refer the grievance to the internal committee for settlement, which the Minister of Finance forms as ZATCA's board chairman. Secondly, sue directly before the circuits. Board Resolution No. (24-02-06) dated 14 Ramadan 1445H, matching 24 March 2024, issued those rules. Settlement negotiates rather than litigates, since the committee turns to negotiation, mediation, or experts. The secretariat studies the request within 10 days of registration and decides whether it enters the agenda. If so, the committee hears the dispute within 60 days, extendable by a similar period with the taxpayer's consent. Item Settlement request Case before the circuits Nature Negotiated, administrative, inside ZATCA Judicial, before an independent circuit Filing window 30 days 30 days Time to decide 60 days, extendable by a similar period 30 days from the first session, plus 15 at most Force of the outcome Ends the dispute once the taxpayer agrees in writing; writ-of-execution force Open to appeal; final at or under 50,000 riyals If it leads nowhere Objection before the circuits within 30 days Appeal, then a petition for reconsideration A settlement request bites at once, since accepting its registration halts a case already before the committees. Nevertheless, letting the response window lapse counts as refusal, so ZATCA's decision stands again and the settlement track counts as never taken. Therefore that window is no administrative courtesy. ![Settlement committee timelines and the finality threshold before the circuits](https://centralcdn.hespah.com/uploads/emils/17913101791.jpeg "Settlement committee timelines and the finality threshold before the circuits") Station three: the case before the first-instance circuits ---------------------------------------------------------- You file through the General Secretariat's electronic system, and the case registers from submission once its particulars are complete. If one is missing, you hold 15 days from notice of the gap; otherwise the case counts as never filed. One rule in Article Eleven kills whole cases: a single statement of claim may not combine more than one objection, since each takes its own case. For example, a firm assessed for three years files three cases, not one. The circuit then rules within 30 days of the first session, while it may extend that by 15 days at most. Station four: appeal, and when a decision turns final ----------------------------------------------------- Appeal circuits decide objections against first-instance decisions. You submit the appeal within 30 days of the day after you receive the decision, carrying its details, its grounds, and the appellant's requests. However, not every decision carries a right of appeal. First-instance decisions turn final in three cases: where the amounts due stay at or under 50,000 riyals, where the appeal window lapses unused, or where the parties reconcile before the circuit. After finality a ZATCA objection ends at a petition for reconsideration, which the issuing circuit hears. Does a ZATCA objection stop payment? ------------------------------------ No, at no station. A ZATCA objection does not change the taxpayer's duty to pay the undisputed amount due in zakat and tax cases. Customs states it more plainly, since collection of established duties and fines continues unless the claimant posts bank or cash security. Approved settlement documents carry the force of writs of execution. Thus ZATCA may proceed to collection and to seizure of funds and assets. Three cases that harden a ZATCA decision ---------------------------------------- Article Six sets out when ZATCA's decision stops being open to grievance anywhere: 1. Where the taxpayer raises no grievance with ZATCA within 60 days of the day after notification. 2. Where he neither sues before the circuits nor seeks referral to the internal committee within 30 days of notice amending or rejecting his grievance, or of 90 days lapsing without a ruling. 3. Where he raises no objection before the circuits within 30 days of notice of the committee's settlement decision, or of the settlement period lapsing. One exception deserves memory: the decision does not harden if the competent circuit finds it fails the statutory requirements. In fact hardening protects a formally sound decision only. Mistakes that sink a ZATCA objection ------------------------------------ Mistake Statutory consequence Counting from the decision date, not the day after notification A count that costs you days, or hides a lapsed window Objecting before paying the undisputed amount, or without a guarantee Published service conditions stay unmet Combining several objections in one statement of claim Article Eleven requires a separate case for each objection Leaving particulars uncompleted for 15 days The case counts as never filed Missing hearings, case struck off for 30 days A ruling of never filed, final and beyond appeal Ignoring the window to accept the settlement outcome It counts as refusal, and the settlement track falls away Most of what sinks a ZATCA objection traces to one cause: the file comes together in the last week. The cure is operational, not legal, since it starts with returns that go out on time — as our [VAT return guide](https://hespah.com/en/blog/vat-return-filing-saudi-arabia) sets out. Frequently asked questions about a ZATCA objection -------------------------------------------------- ### How long is the ZATCA objection deadline? A ZATCA objection takes 60 days for the grievance with ZATCA, counted from the day after notification. ZATCA must rule within 90 days, leaving 30 days to move to settlement or to the circuits. ### Can I go straight to court without settlement? Yes. Article Five gives the aggrieved party two choices inside the thirty days: refer the grievance to the internal committee, or sue directly before the circuits. ### Which body hears the case? The zakat and tax first-instance circuits, then the appeal circuits, all under the General Secretariat of the Zakat, Tax and Customs Committees. Filing runs electronically. ### Does settlement stay open while a case runs? Yes, at any stage, since accepting the request's registration halts the case. Customs smuggling cases stand apart, because they follow their own reconciliation track. ### Does the same path cover the real estate transaction tax? Yes, it counts among the indirect taxes under the same rules. For scope and exemptions see our [article on the real estate transaction tax](https://hespah.com/en/blog/real-estate-transaction-tax-saudi), and likewise [zakat versus income tax](https://hespah.com/en/blog/zakat-vs-income-tax-saudi) for the difference between the two assessments. Sources ------- - [Zakat, Tax and Customs Committees work rules](https://gstc.gov.sa/ar/DocumentsLb/Regulations/Documents/100.pdf) — General Secretariat of the Committees, Royal Order No. (25711) dated 8 Rabi al-Akhir 1445H. - [Guideline on settling zakat, tax and customs disputes](https://zatca.gov.sa/ar/HelpCenter/guidelines/Documents/Zatca_Lijan_Guideline.pdf) — ZATCA, second edition, August 2026. - [Objection on re-assessment service](https://zatca.gov.sa/ar/eServices/Pages/eServices-020.aspx) — conditions and requirements. At Hespah Academy we teach the ZATCA objection hands-on within our [tax and accounting courses](https://hespah.com/en/courses). *This article serves informational purposes, and it does not replace official sources or professional advice before you act.* Articles you might like ----------------------- [![Nitaqat Wage Floor Rises to SAR 5,000 Then SAR 6,000](https://centralcdn.hespah.com/265/conversions/cover-sm.webp)2026-10-26 ### Nitaqat Wage Floor Rises to SAR 5,000 Then SAR 6,000 The Nitaqat wage floor rises to SAR 5,000 after six months and SAR 6,000 after twelve, by royal directive of 25 October](/en/blog/nitaqat-wage-floor-2026)[![UAE e-Invoicing: the Provider Deadline Falls on 30 October](https://centralcdn.hespah.com/263/conversions/cover-sm.webp)2026-10-26 ### UAE e-Invoicing: the Provider Deadline Falls on 30 October E-invoicing in the UAE: appoint an accredited service provider by 30 October 2026 if revenues reach AED 50 million; go l](/en/blog/uae-einvoicing-asp-deadline)[![Reclaiming VAT on Real Estate Supplies: a 30-Day Window](https://centralcdn.hespah.com/181/conversions/cover-sm.webp)2026-10-14 ### Reclaiming VAT on Real Estate Supplies: a 30-Day Window ZATCA Board Resolution 10-04-26, published 13 October 2026, opens a VAT refund on real estate supplies made by individua](/en/blog/vat-real-estate-supplies-refund)[![Real Estate Transaction Tax in Saudi Arabia: Scope and Exemptions](https://centralcdn.hespah.com/118/conversions/cover-sm.webp)2026-10-04 ### Real Estate Transaction Tax in Saudi Arabia: Scope and Exemptions How the Saudi real estate transaction tax works: the 5% rate, what falls in scope, out-of-scope versus exempt, 21 exempt](/en/blog/real-estate-transaction-tax-saudi)[![VAT Penalties in Saudi Arabia and How to Avoid Them](https://centralcdn.hespah.com/81/conversions/cover-sm.webp)2026-10-01 ### VAT Penalties in Saudi Arabia and How to Avoid Them All VAT penalties in Saudi Arabia: the statutory table by article, the field ladder from warning to SAR 50,000, and the](/en/blog/vat-penalties-saudi-arabia) [![Hespah LLC](https://centralcdn.hespah.com/home_logolight_file2png.webp)](/en)Tax and Accounting Professional Training [Hespah ](/en)[Courses](/en/courses)[Blog](/en/blog)[Contact us](/en/contact)[Partners & Discounts](https://hespah.com/partners) [Policies ](https://hespah.com/privacy-policy)[Privacy Policy](https://hespah.com/privacy-policy)[Usage and Refund Policy](https://hespah.com/refund-policy) ### Contact us New Castle, DE, 19720 US ### Follow us [](https://www.facebook.com/HespahCo)[](https://www.instagram.com/hespahco)[](https://www.linkedin.com/company/hespahco/)[](https://x.com/hespahco)[](https://www.tiktok.com/@hespahco) ### Payment methods Visa Mastercard Apple Pay All Rights Reserved Hespah LLC © 2026 , Developed by [10 - Ashara](https://10ashara.com)