Financial
EARLY ELIGIBILITY ASSESSMENT AND PRE-APPROVAL CRITICAL UNDER UAE R&D TAX CREDIT RULES

The UAE Ministry of Finance has issued Ministerial Decision No. 24 of 2026, setting out the detailed implementation rules for the country’s first-ever Research and Development (R&D) Tax Credit regime under the Corporate Tax framework. Effective for Tax Periods commencing on or after 1 January 2026, the decision establishes a progressive, tiered credit structure with rates of 15%, 35% and 50%, linked to both the level of qualifying R&D expenditure and the number of R&D staff employed. The maximum qualifying expenditure is capped at AED 5 million per entity or Tax Group per year.
“The R&D Tax Credit is a landmark development, but it is not a simple year-end adjustment. The dual-threshold design means this is as much a workforce planning exercise as a tax planning one. Businesses need to understand that pre-approval from the Council is mandatory before any credit can be claimed – this is a precondition, not an administrative formality. Companies that begin mapping their R&D activities against the Frascati Manual criteria, quantifying qualifying expenditure and building their documentation framework now will be in the strongest position when it comes time to file,” said Nimish Goel, Leader Middle East, Dhruva, Ryan LLC Affiliate.
The move represents one of the clearest signals yet that the UAE intends its tax framework to actively incentivise innovation, influence capital allocation and support the country’s long-term economic diversification going well beyond revenue collection and international alignment. For businesses operating in manufacturing, technology, engineering, healthcare, food and beverage, agriculture, and other innovation-led sectors, the key consideration is whether internal systems are equipped to capture the benefit.
The credit operates on a dual-threshold basis that is unlike most international R&D incentive regimes. To access each tier, a business must satisfy both a minimum qualifying expenditure level and a minimum average R&D headcount. The first AED 1 million of qualifying spend attracts a 15% credit, requiring at least two R&D staff. The portion between AED 1 to 2 million qualifies at 35%, requiring at least six staff. Spend between AED 2 to 5 million qualifies at 50%, requiring at least fourteen staff. If the headcount threshold is not met, the credit rate drops to the highest tier where both conditions are satisfied, creating material cliff-edge effects that make workforce planning an integral part of tax planning for the first time in the UAE.
Qualifying R&D activities must meet five criteria drawn from the OECD Frascati Manual; they must be novel, creative, uncertain in outcome, systematic, and transferable or reproducible. Activities in social sciences, humanities and the arts are excluded, and only R&D conducted within the UAE qualifies. Qualifying expenditure falls into three categories: staff costs (which receive a 30% overhead uplift), consumable costs, and subcontracting fees paid to UAE-based contractors. Intra-group transactions are consistently excluded from qualifying expenditure, a design choice that will require groups with centralised R&D functions to review their cost allocation and transfer pricing arrangements carefully.
The decision also introduces a mandatory pre-approval process administered by the Council, ongoing compliance reporting obligations, and a seven-year record-keeping requirement for technical documentation covering R&D objectives, methodologies, experiments and findings. These requirements signal that the UAE authorities expect robust, contemporaneous evidence of qualifying activities, not retrospective assembly at the time of filing.
Commenting on the development, Justin Arnesen, Principal, Practice Leader, Europe & Asia Pacific Innovation Funding, Ryan, said, “Ryan’s global experience in R&D tax credits shows that the difference between a policy announcement and a commercial outcome lies in the rigour of eligibility analysis, documentation and claims management. We have helped UK businesses receive over AED 2.5 billion in innovation funding through R&D Tax credits. These outcomes were driven by disciplined processes, not just the existence of a credit. This initiative not only aligns with global best practices but also sends a clear signal to multinational organisations and emerging enterprises that the UAE is serious about fostering a knowledge and innovation-based economy.”
Implications for Multinational Groups under Pillar Two
For multinational groups within the scope of the UAE’s Domestic Minimum Top-up Tax (DMTT), the R&D Tax Credit adds an important layer to Effective Tax Rate (ETR) modelling. Because the credit is non-refundable, it is likely to be treated as a reduction of covered taxes under the Global Anti-Base Erosion (GloBE) rules rather than as a Qualified Refundable Tax Credit, a distinction that can lower the jurisdictional ETR rather than improve it. For groups operating at or near the 15% minimum rate, this means the credit could paradoxically increase Top-up Tax exposure even as it reduces Corporate Tax liability.
However, the decision provides a mechanism for unutilised credits to offset top-up tax directly through the Domestic Group structure, which partially mitigates this effect. Multinationals should model the net impact across both Corporate Tax and top-up tax before claiming, and factor in the five-year claw-back provision that applies if the entity’s status changes – including becoming a qualifying free zone person or redomiciling outside the UAE.
For businesses with cross-border operations, the commercial value of the R&D Tax Credit extends beyond the direct tax saving. The credit’s treatment in the group’s wider international tax profile, including its classification under tax treaties, its interaction with Pillar Two ETR calculations, and its impact on transfer pricing for cost contribution arrangements will require integrated advisory across multiple disciplines. Groups conducting joint R&D through cost contribution arrangements should note that only the arm’s length share of contributions attributable to UAE-based R&D qualifies, adding a transfer pricing dimension to credit planning. The Ministerial Decision applies to Tax Periods and Fiscal Years commencing on or after 1st January 2026.
“The UAE has built a thoughtful, well-structured framework with clear international lineage – the Frascati Manual criteria, the tiered incentive design, the Pillar Two integration. Early investment in activity mapping, expenditure tracking and documentation is likely to determine the extent to which businesses can access and sustain benefits under the regime,” concluded Nimish.
Financial
Al Ansari Exchange Partners with RTA Dubai to Offer nol Travel Cards
Al Ansari Exchange, the UAE’s leading remittance and foreign exchange company and a subsidiary of Al Ansari Financial Services PJSC (DFM: ALANSARI), has partnered with Dubai’s Roads and Transport Authority (RTA) and in association with MDX Technology Solutions ME, to make nol Travel Cards available at selected branches across Dubai.
The collaboration broadens Al Ansari Exchange’s portfolio of third-party products and extends access to Dubai’s integrated mobility payment system through the UAE’s largest branch networks. It also reflects the company’s strategy of building a connected physical and digital ecosystem that provides customers with convenient access to a wider range of everyday financial and lifestyle services.
Residents and visitors can now purchase nol Travel Cards from selected Al Ansari Exchange branches, distributed through MDX Technology Solutions ME, the RTA-authorised distributor of nol Travel Cards, providing an additional point of access to one of Dubai’s most widely used mobility payment solutions.
The nol Travel Card enables cashless payments across Dubai’s public transport network, including the Dubai Metro, Dubai Tram, public buses, marine transport and public parking. It is also accepted at more than 14,000 retail outlets across the UAE. Through the nol Pay App, cardholders can access more than 200 lifestyle offers and discounts.
Commenting on the collaboration, Musad Ibrahim Alhammadi, Director of Automated Collection Systems at Corporate Technology Support Services Sector, Roads and Transport Authority (RTA), said: “Expanding the availability of nol Travel Cards through strategic collaborations supports RTA’s efforts to make mobility services more accessible across Dubai. Providing additional distribution channels contributes to wider adoption of digital payment solutions and enhances the travel experience for residents and visitors.”
Ali Al Najjar, Chief Executive Officer of Al Ansari Exchange, added: “As customer expectations continue to evolve, we are expanding the role of Al Ansari Exchange beyond traditional financial transactions by bringing together financial, payment and everyday lifestyle services through both our branch network and digital platforms. Making nol Travel Cards available through our branches complements our broader strategy of creating a seamless customer experience while supporting Dubai’s vision for a smart, digitally connected city.”
Financial
The rights you think you have: five legal stress tests for a more resilient business
Resilience is not only about cash reserves, backup servers or alternative suppliers. It also depends on whether a company’s legal rights and permissions still work when the business is under pressure.
By: Maroun Abou Harb, Associate at BSA LAW
Resilience is discussed as an operational or financial discipline. Businesses test liquidity, back up systems and diversify supply chains. Yet every continuity plan rests on legal infrastructure: licenses, delegated authorities, contracts, data permissions, employment arrangements, security rights and evidence.
That infrastructure can fail when needed most. The replacement supplier cannot be appointed without third-party consent. Customer data cannot lawfully be moved to the backup provider. An insurance claim is compromized by late notification. A guarantee was signed incorrectly. The company owns a platform, but not all of its intellectual property.
The most dangerous legal risk is not the missing clause. It is the right management assumes the business has, but cannot use.
In the UAE, the Central Bank’s 2026 Operational Risk Management Regulation now requires licensed financial institutions to implement a comprehensive operational risk and resilience proecedure. The principle is valuable for every company: identify what must continue, locate the legal points of failure and test them before disruption does.
- Can the business lawfully act?
Start with corporate authority, check that licenses match actual activities, constitutional documents reflect the ownership and governance structure, and beneficial-owner, shareholder and director records are accurate. Review reserved matters, signing matrices, powers of attorney and banking mandates.
A deal, borrowing or emergency payment can stall because the authorized signatory is unavailable, a power has expired or an approval threshold was misunderstood. Group companies should confirm which entity employs people, owns assets, contracts with customers and receives revenue.
Run this scenario: if the chief executive and chief financial officer were unreachable tomorrow, who could bind the company, access its accounts and appoint an alternative supplier? If the answer is uncertain, the business has a legal single point of failure.
- Which contracts become dangerous under stress?
Most contract reviews examine value and liability. A resilience review asks a different question: what happens when performance is interrupted?
Build a heat map of critical customer and supplier contracts, ranked by operational importance and consequence of failure. For each, test termination and suspension rights, force majeure and change-in-law provisions, service levels, price-adjustment mechanisms, liability caps, indemnities, insurance, governing law and dispute forum, subcontracting, assignment and change-of-control restrictions. Check notice methods and cure periods; a valuable right can disappear if a notice is sent late or to the wrong address.
Then examine optionality, can the company use a replacement supplier, obtain transition assistance, retrieve its data in a usable format and continue using essential intellectual property? Is there a source-code escrow or step-in mechanism where appropriate?
The aim is not to renegotiate every contract. It is to know which five contracts could stop the business and to fix those first.
- Can technology fail without the legal part failing too?
A technical recovery plan is incomplete if the contracts do not support it. Cloud, payment, telecommunications and managed-service arrangements should align promised recovery times with the company’s tolerance for disruption. Audit rights, incident cooperation, subcontractor controls, data-location commitments and exit assistance should be tested.
The incident playbook must allocate legal decisions. Who determines whether regulators, customers, insurers or affected individuals must be notified? Who preserves evidence and engages external advisers? How will legal privilege or professional confidentiality be preserved? A cyber incident moves quickly; ambiguity over decision-making wastes the hours that matter most.
Conduct an exercise with management, technology, legal, communications and finance. Introduce a realistic vendor outage or data breach and follow the contracts: who calls whom, what must be notified, and what can actually be recovered?
- Does the company know what data and technology it is using?
Across the GCC, privacy and cybersecurity regimes increasingly regulate how data is collected, processed, retained, transferred and protected. A company cannot comply, or recover confidently, without knowing where its data goes.
Create a data map covering customers, employees, vendors and website users. Record the purpose and legal basis for processing, storage location, access rights, retention period, cross-border transfers and third-party processors.
The same exercise should include artificial intelligence, by identifying public and embedded AI tools, the information supplied to them, the outputs relied upon and the human review applied. Confidential information, personal data and third-party intellectual property should not enter a tool because an employee can access it. An approved-use policy, procurement review and output-verification process are proportionate safeguards.
- Can the company protect value when conditions deteriorate?
Management should monitor covenant breaches, unpaid taxes, overdue receivables, expiring insurance, threatened claims and counterparties showing signs of insolvency. The legal team should know which rights permit suspension, security enforcement, contract termination or protective court relief, and whether exercising them could create risk.
People and intellectual property also require continuity planning. Confirm that employment and consultancy terms contain appropriate confidentiality, invention-assignment and post-termination protections, tailored to the governing law. Identify key-person dependencies, succession gaps and access held by departing staff. Register intellectual property where appropriate and maintain evidence of creation and ownership.
Business needs also to review insurance as a contract, not a certificate. Map material risks to coverage, exclusions, deductibles, notification deadlines and consent requirements. The policy is only useful if the company knows how to activate it.
In brief, the output should be that for every critical risk, record the business service affected, relevant entity and contract, responsible owner, required action, deadline and escalation threshold.
Report the highest exposures to the board and repeat the exercise after major acquisitions, restructurings, regulatory changes or technology deployments.
A focused review can produce four useful assets:
- an authority and obligations calendar;
- a critical-contract heat map;
- a data and AI inventory; and
- a tested incident playbook.
No company can remove disruption. It can, however, remove the uncertainty surrounding who may act, what must be done and which rights remain available.
Financial
Tax Is Not a Strategy – Why Dubai’s Smartest Founders Think Beyond Zero Per Cent
By Joe David, CEO of Nephos Group
“Move to Dubai for tax.”
I hear this constantly. From founders, investors, crypto-native operators – people building real businesses who reduce one of the biggest decisions of their professional lives to a single line on a spreadsheet.

And honestly, it is the wrong way to think about it.
Tax should rarely be the sole reason to relocate. When it is, it is usually where things go wrong. The corporate structure is not set up correctly. The banking relationships are not in place. The founder leaves within 18 months because the deeper rationale was never really there. I have seen this pattern play out dozens of times over the past decade, and it almost always traces back to the same root cause: a decision built on a tax rate rather than a strategy.
The tax-first trap
Dubai’s zero per cent personal income tax rate is real, and it is significant. But leading with tax creates a narrow frame that obscures the fuller picture. Founders who relocate purely for a rate often fail to consider the operational realities of building in a new jurisdiction. They underestimate the compliance infrastructure required to make the move defensible. They overlook the substance requirements that tax authorities in their home countries will scrutinise. When the expected savings do not materialise cleanly, because the structure was an afterthought, disillusionment sets in fast.
This does Dubai a disservice. It reduces a genuinely world-class business environment to a line in a tax planning brochure. The city deserves better than that, and so do the founders making life-altering decisions based on incomplete thinking.
What the successful ones actually optimise for
The founders and investors who get the most out of Dubai are not chasing a tax rate. They are making a broader strategic move.
Jurisdictional access is a major factor. Dubai sits at the crossroads of Europe, Africa and Asia, offering time zone coverage and travel connectivity that few cities can match. For businesses operating across multiple markets, particularly in digital assets, fintech and professional services, that geographic positioning is a genuine competitive edge.
Then there is the capital environment. Dubai has become a magnet for institutional and private capital, with fund structures, family offices and venture vehicles establishing a permanent presence. The banking infrastructure, while still maturing in certain areas, has improved significantly. For crypto-native businesses in particular, the regulatory clarity offered by frameworks like the Virtual Assets Regulatory Authority (VARA) provides something that many Western jurisdictions still cannot: a clear, codified path to operating legally with digital assets.
The business ecosystem itself is another draw. The speed at which you can incorporate, hire, open accounts and begin operating is remarkable compared to legacy jurisdictions. Free zones offer tailored licensing, and the government’s responsiveness to emerging sectors – AI, blockchain, tokenised finance – signals a jurisdiction that is building forward rather than regulating backward.
And then, yes, there is the lifestyle. Climate, safety, connectivity, quality of infrastructure. These are not trivial considerations when you are asking a founding team to commit to a base for the next five to ten years.
Tax is often the outcome of all of this. It is not the strategy itself.
The compliance landscape is shifting
There is another reason the tax-first mindset is increasingly risky. The global compliance environment is tightening rapidly. The Crypto-Asset Reporting Framework (CARF), developed by the OECD, will require automatic exchange of information on crypto transactions between jurisdictions. The EU’s DAC8 directive introduces similar obligations across member states. The days of relocating and assuming your home country’s tax authority will not follow are numbered.
This means that substance, genuine economic activity, real operational presence, defensible corporate structures, matters more than ever. A Dubai relocation that is purely cosmetic will not survive scrutiny. One that is built on genuine strategic foundations, with proper advisory support and compliant structures, will.
The conversation worth having
None of this is an argument against moving to Dubai. Quite the opposite. For the right founder, with the right business, at the right stage, it can be a transformative decision. But that decision needs to be grounded in strategy, not arithmetic.
Before you start calculating your tax savings, ask the harder questions. Does your business model benefit from being in this jurisdiction? Can you build genuine substance here? Are your corporate structures defensible under international reporting frameworks? Do you have the advisory infrastructure to get this right from day one?
That distinction – between tax as a tactic and strategy as a foundation – matters more than most people realise. And it is a conversation worth having before you make any decisions.
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