The FTA’s Taxation Residency Certificate (TRC) User Guide sets out that ‘in order to be eligible to apply for a TRC, the legal person must have been established for a period of at least one year’.
In our opinion, this requirement is behind the times. It appeared in 2021 long before Corporate Tax has been introduced in the UAE and special rules for determining tax residency has been released in 2022.
You may try enclosing this kind of letter to your application with the FTA. The success is not guaranteed. But, at least you have arguments for the reconsideration request or for objections to the Tax Dispute Resolution Committee.
