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

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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.

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FOUR DISCIPLINES UAE BOARDS NEED BEFORE E-INVOICING GOES LIVE

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Amit Dua, President, SunTec Business Solutions

E-invoicing in the UAE is no longer a distant policy idea; it is a dated commitment. From July 2026, the Federal Tax Authority (FTA) will begin the first mandatory phase of a national e-invoicing regime, with larger taxpayers required to comply from January 2027 and smaller businesses following later that year. Penalties of up to AED 5,000 per violation have already been announced for non-compliance.

This is happening against the backdrop of a fast-expanding non-oil economy. At the same time, artificial intelligence is projected to contribute close to 14 percent of UAE GDP by 2030, the highest relative impact in the region.

In such an environment, e-invoicing is not a narrow tax exercise. It is a test of whether companies can manage real-time regulatory obligations while improving the speed, integrity, and usefulness of their financial data. Firms that treat it as another compliance chore will scramble to catch up. Those that approach it as a strategic capability will emerge with cleaner processes, faster cash conversion, and better insight into how their businesses actually work.

Four disciplines, in particular, will separate the merely compliant from the genuinely prepared.

1. Start by really understanding the new rulebook

The first discipline sounds obvious but is frequently ignored: know the rules in detail. Under the UAE framework, an invoice will no longer be a PDF attachment travelling quietly from seller to buyer. It will be a structured data packet, typically in XML, and in some cases JSON, that must be generated by the supplier’s systems, routed through an accredited service provider operating on the Peppol five-corner model, and delivered simultaneously to the buyer and to the FTA.

This architecture is deliberately more complex than the old email-and-attachment world. Each invoice must pass schema checks, integrity checks, and business-rule validations before it is accepted as a tax-compliant document. The FTA will then use the incoming data stream to pre-populate returns, reconcile declarations with actual invoice flows, and flag discrepancies almost in real time.

There is also a long tail of procedural obligations. Businesses must understand which transactions fall within scope in each phase, how credit notes and cancellations will be handled, how to deal with cross-border supplies, and which exemptions, if any, apply to their sector. Beneath all of this sits a familiar but often neglected requirement: record-keeping. UAE tax law already obliges businesses to retain accounting records, including tax invoices, for at least five years after the end of the relevant tax period, with longer periods for certain assets and real estate. E-invoicing will not replace this obligation; it will tighten it, because the Authority will have its own copy of every invoice.

Companies that only half-understand this rulebook will find themselves constantly reacting to surprises. The ones that invest early in a precise, shared understanding, across finance, tax, IT and operations, will be able to design systems and processes that meet the requirements without strangling the business.

2. Redesign the systems, not just patch them

The second discipline is technical, but it cannot be delegated entirely to IT. Large and mid-sized UAE businesses typically run a patchwork of ERPs, billing engines, and industry-specific platforms. Many were built for a world where an “invoice” was whatever the system could print. They were not designed to produce standardized, structured e-invoices or to connect to a Peppol-based network in which every document is validated by an external access point before it counts.

Trying to bolt e-invoicing on to this kind of landscape in the last quarter of 2026 would be professionally reckless. Boards must insist on a hard-headed mapping of how invoices are currently created, routed, approved, and stored.

The UAE framework gives firms some architectural freedom. They can consolidate invoice generation in a central “hub” that talks to multiple access points, or they can adopt a more decentralized model with business-unit-specific systems feeding into a common provider. But there are hard deadlines. Large taxpayers with annual revenues above AED 50 million must appoint an accredited service provider by 31 July 2026 and go live with e-invoicing by 1 January 2027; smaller taxpayers follow six months later, with their own appointment and go-live dates in 2027.

Accredited service providers themselves face strict requirements on uptime, performance, and information security. Many must demonstrate ISO/IEC 27001-level controls and keep pace with evolving FTA specifications. Choosing one in a hurry, without proper due diligence on their scalability and roadmap, will store up trouble. The more disciplined approach is to treat system redesign as a staged program: clean up master data, rationalize templates, decide which systems are sources of truth and which are consumers, and only then build or buy the integration layer that connects to the Peppol network.

3. Train the organization for real-time tax

The third discipline is organizational. E-invoicing looks, at first glance, like a back-office affair. In reality, it will touch sales, procurement, operations, customer service, and even treasury. Every group that raises, approves, disputes or chases an invoice will have to change behavior.

In markets that have already implemented similar regimes, many of the worst early-stage problems had little to do with software. They arose from people trying to work around the new rules. Sales teams promised bespoke formats or unusual discount structures that the system could not express in a valid e-invoice. Shared service centers reverted to spreadsheets when confronted with a new edge case. Managers asked IT to “override” rejections to recognize revenue faster, undermining both controls and audit trails.

The UAE will not be an exception. Training cannot be limited to a single webinar or a set of user manuals. Front-line staff need to understand what makes an invoice “real” in the new world, which fields are non-negotiable, and what to do when an invoice fails validation. Middle managers need to know how to interpret new exception reports and how to balance commercial pressures with compliance obligations. Senior leadership needs a clear view of key metrics such as rejection rates, average time from issue to acceptance, and the volume of manual interventions as leading indicators of whether the new regime is bedding in or beginning to buckle.

The most effective organizations are already running “shadow” or pilot cycles, issuing e-invoices alongside traditional ones and using the results to refine processes ahead of the legal deadlines. That kind of rehearsal requires coordination, and coordination requires visible sponsorship. When the CEO, CFO and CIO jointly own e-invoicing, it becomes a transformation initiative. When it is dumped quietly into the IT work queue, it becomes an expensive troubleshooting exercise.

4. Treat data, security, and retention as strategic infrastructure

The fourth discipline goes beyond the launch date. E-invoicing will generate one of the richest, most sensitive data streams in a business. Each invoice reveals who is paying whom, on what terms, for what goods or services, and under what tax treatment. In the UAE’s Peppol-based five-corner model, this data will flow more widely than before, passing through access points and central systems on its way to the FTA.

Regulators have attempted to pre-empt security concerns. Accredited providers must meet rigorous information-security standards, and the technical specifications call for encryption, digital signatures and auditable logs. But no external standard can compensate for weak internal governance. Boards must be asking very basic questions now: who can change tax codes or customer master data; how access rights are granted and revoked; what happens if an access point is compromised or goes offline; and how quickly the company can detect unusual patterns, such as repeated rejections for a particular counterparty.

Record-keeping deserves similar attention. Existing VAT rules already require businesses to retain tax records, including invoices, for at least five years after the end of the relevant tax period, with longer retention periods for some categories. E-invoicing will make it easier to store these records in a structured way, but it also raises the bar. If the Authority holds a copy of every invoice, gaps or inconsistencies in a company’s own archive will be harder to explain.

If managed well, this new data environment is an asset. Structured e-invoice data can give leadership teams a real-time view of receivables, payables, pricing, and discount patterns across business units and geographies.

From four steps to one mindset

The UAE’s e-invoicing mandate will not dominate headlines in the way that new trade agreements or record non-oil trade figures do. Yet, quietly, it will shape how companies in the country bill, collect, report and plan. It is tempting for boards to think of it as a discrete project with a defined end date. In reality, it marks a shift to a more transparent, data-intensive relationship between business and state, one that will continue to evolve as tax rules, digital infrastructure, and trade flows change.

The four disciplines outlined here, understanding the rulebook, redesigning systems, training the organization, and treating data and security as strategic infrastructure, are not an exhaustive checklist. They are, however, a good proxy for mindset. Companies that embrace them are likely to find that e-invoicing improves the quality of their numbers, the speed of their decisions and the robustness of their controls. Those that do not, may meet the letter of the law but miss the larger opportunity.

In a country positioning itself as a global hub for trade and AI-driven digital commerce, e-invoicing is part of the plumbing. As every good engineer knows, the quality of the plumbing determines how much pressure the system can take.

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INSIDE THE NEW RISK REALITY FACING GCC TRADE AND LOGISTICS

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Exclusive interview with Aurélien Paradis, CEO of AU Group MEA

How Supply Chain Disruptions Are Reshaping Trade Across the GCC?

What we are seeing across the GCC is a reset in how trade moves. Goods are still flowing, but the routes, timelines, costs, and risk assumptions behind them are changing. That is the real shift businesses are now dealing with. The pressure on key shipping corridors has forced companies to rethink the way they move goods across the region. Many are having to re-route shipments, work with a wider mix of logistics partners, and rely more heavily on alternative models such as land bridge solutions or sea-air combinations. At the same time, higher freight costs, with carriers introducing surcharges ranging from USD 1,500 to USD 4,000 per container, rising insurance premiums, and longer transit times, with the rerouted sailings adding around 10- 14 days, are putting additional pressure on already tight supply chains.

For businesses in the GCC, this creates a very different operating environment. Essential imports, raw materials, and industrial inputs may still arrive, but not with the same predictability companies were used to. And once predictability is lost, the impact is felt well beyond logistics. It affects project timelines, inventory planning, customer commitments, and ultimately working capital. Even with the re-opening of the Strait of Hormuz, it will take time to make-up for the delays. So, the real story is this: trade in the GCC is continuing, but under a new risk and cost structure. Companies that adapt fastest, by building more flexibility into sourcing, transport, and risk planning, will be in a much stronger position than those still relying on old trade assumptions.

Why GCC Companies must Rethink Credit Risk in a Volatile Trade Environment?

At its simplest, trade credit insurance exists to protect a business when a customer cannot pay for goods or services. It is built on a basic commercial truth: a sale is only complete when the cash is collected. In more stable conditions, many companies treat that risk as manageable and assume late payment can be absorbed. The problem today is that volatility is changing the risk much earlier in the trade cycle.

Receivables are often one of the largest assets on the balance sheet, so when they come under strain, the effect is immediate on cashflow and working capital. The stronger businesses will be the ones that reassess buyer quality earlier, stay closer to payment behaviour, and act before stress becomes loss. In this environment, protecting the receivable is just as important as moving the goods.

Why Trade Credit Insurance Is Gaining Importance in the GCC

Because businesses are operating in a market where uncertainty is no longer occasional; it is becoming part of the trading environment itself. In that kind of climate, companies are paying closer attention not just to how much they sell, but to how securely they can sell on credit. The value of trade credit insurance is that it does not only protect against non-payment. It also gives businesses a more informed view of the customers they are trading with and the level of exposure they are carrying. That becomes particularly important when supply chain disruption, rising costs, and liquidity pressure can weaken a buyer’s position quite quickly.

What is changing is the way companies are looking at the tool. It is no longer seen only as a defensive measure used after something goes wrong. More businesses are using it as a way to trade with greater confidence, protect cashflow, and make better credit decisions while conditions remain volatile. It can also strengthen access to financing, because insured receivables are often viewed more positively by lenders. In that sense, trade credit insurance is gaining relevance not only because risk is rising, but because it helps businesses stay commercially active without taking unnecessary exposure. The companies that understand this are treating it less as a safety net and more as part of a stronger growth strategy.

What are the biggest logistical challenges currently affecting GCC businesses?

The biggest issue at the moment is that companies are not facing just one logistical challenge, but the piling up of several at once. Businesses are dealing with route disruption, longer transit times, capacity pressure at alternative ports, customs and documentation delays as cargo is redirected, and higher transport and insurance costs as carriers adjust to a more volatile operating environment. Even when goods can still move, they are not always moving through the most efficient or predictable channels, which makes planning far more difficult for importers, distributors, and project-led businesses. That loss of predictability is often the most disruptive part, because it affects everything from inventory timing to delivery commitments and resource allocation.

What can make things more serious and with a lasting impact is the scale and the duration of the disruption. In practical terms, that means companies must now incorporate higher risk for rerouting, and delays rather than treating them as exceptions in the GCC region. The businesses managing this best are the ones increasing flexibility in routing, diversifying logistics partners, and planning for disruption as a recurring operating condition rather than a temporary shock

Q5. Which sectors are most vulnerable to supply chain disruptions?


Several industries across the GCC are feeling the sharpest impact from current supply chain disruption, particularly those that rely heavily on global shipping routes, imported inputs, or time-sensitive delivery cycles. Food and FMCG remain among the most exposed, especially within the cold chain, where fresh produce, meat, dairy, and other perishables depend on strict timing and uninterrupted movement. Manufacturing and industrial sectors are also under pressure, as delays in raw materials and inbound components can slow production, raise inventory costs, and strain working capital.

Construction and building materials face similar challenges, with many projects across the region dependent on imported supplies, meaning longer transit times can lead to delays, cost overruns, and pressure on already demanding timelines. Energy-linked industries are not immune either, as refinery inputs and critical equipment still move through affected shipping lanes. Automotive, electronics, and retail have also been hit by detours around Africa, which are creating shortages and pushing out delivery schedules for consumer goods.

At the same time, SMEs across all trading sectors remain especially vulnerable, as thinner margins and lower liquidity leave them less able to absorb delayed settlements or sudden disruption. Despite these pressures, the region remains highly resilient, and one clear outcome of the current environment is that businesses are being pushed toward stronger supply diversification, tighter financial discipline, greater use of credit risk tools, wider adoption of trade credit insurance, and more serious investment in supply chain agility.

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MOZN’s AI-Powered FOCAL Platform Earns Recognition in Forrester Financial Crime Landscape

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MOZN, a leading enterprise AI company, today announced that it has been named among notable vendors in Forrester’s Financial Crime Management Solutions Landscape Q1 2026 report. This inclusion marks a significant milestone for MOZN and reinforces its position among global innovators.


The Forrester report, which lists 42 vendors, provides financial institutions with an overview of notable vendors and the key market dynamics shaping the rapidly evolving financial crime management (FCM) market, including fraud and anti-money laundering (AML) solutions.


MOZN was listed in the report with a geographic focus on Europe, the Middle East, and Africa (EMEA) and the Asia-Pacific (APAC) regions, and an industry focus on financial services, government, and insurance. The recognition underscores the company’s sustained investment in AI-driven innovation and its focus on delivering scalable, future-ready financial crime solutions tailored to high-growth and complex regulatory markets.


At the center of this recognition is FOCAL, MOZN’s end-to-end financial crime management platform. Built on a unified FRAML (Fraud + AML) architecture, FOCAL leverages agentic AI to automate data integration, accelerate risk-scoring, and streamline alert triage, enhancing investigator productivity while preserving human judgment. The platform offers flexible deployment options, allowing organizations to modernize their operations in a way that aligns with their technical and regulatory needs.


“MOZN’s inclusion in Forrester’s report reflects the progress we have made in building technology that truly transforms how institutions combat financial crime,” said Dr. Mohammed Alhussein, Founder and CEO of MOZN. “As Saudi Arabia designates 2026 as the Year of Artificial Intelligence, it reinforces the Kingdom’s ambition to lead in shaping the future of AI globally. At MOZN, we are proud to contribute to this vision by engineering AI-native platforms that make financial crime prevention more proactive, precise, and effective. This milestone reflects both the momentum of our mission and the growing global relevance of technology built in the region.”


By combining deep regional expertise with global technology standards, MOZN continues to advance its purpose of empowering organizations with intelligence that matters. The company remains committed to delivering AI-native solutions purpose-built for the world’s most regulated and knowledge-intensive sectors, enabling institutions to operate with greater clarity, confidence, and control. As demand for advanced AI-driven capabilities accelerates worldwide, MOZN is expanding its global footprint, supporting organizations as they navigate an increasingly complex financial crime landscape.

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