R&D tax credit legislation

Core published decisions (MoF)

Start with the two instruments that most teams bookmark day-to-day:

1. Cabinet Decision No. 215 of 2025 on the Research and Development Tax Credit for purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (as amended). Official English PDF (MoF). This decision contains the framework definitions and rules for the R&D Tax Credit, including Qualifying Entity, Qualifying R&D Activity, Qualifying R&D Expenditure, excluded entities, conditions to claim, qualifying expenditure categories and conditions, utilisation and carry-forward rules, and claim submission requirements.
2. Ministerial Decision No. 24 of 2026 on the implementation of certain provisions of Cabinet Decision No. 215 of 2025. Official English PDF (MoF). This decision contains the implementation mechanics, including the tiered rate table and thresholds, the definition of R&D Staff, conditions for Qualifying R&D Activities (with Frascati Manual reference), mandatory Council pre-approval, detailed expenditure rules (including Staff Costs and a 30% uplift), record-keeping requirements, transfer and grouping rules, and anti-abuse provisions.

Policy launch context (helpful for understanding intent, not a substitute for law): MoF — UAE launches Phase 1 of the Research and Development Tax Incentives Programme.

Parent law: Federal Decree-Law No. 47 of 2022 (Corporate Tax)

The R&D credit is not interpreted in isolation. Corporate tax residence, grouping, QFZP rules, transfer pricing documentation, and filing obligations all flow from Federal Decree-Law No. 47 of 2022 and related cabinet and ministerial decisions. When you read Cabinet Decision No. 215 of 2025, cross-reference defined terms (for example, “Taxable Person”, “Tax Period”, “Qualifying Free Zone Person”) to the corporate tax law and FTA guidance applicable to your fact pattern.

Practical tip: keep a single “definition map” spreadsheet linking each term used in your R&D model to the article or schedule where it is defined—then update it whenever MoF or FTA text changes.

Federal Tax Authority: administration and guidance

The Federal Tax Authority (FTA) administers corporate tax registration, returns, payments, and compliance reviews. R&D credit claims must ultimately be consistent with your corporate tax filings and supporting records in the FTA ecosystem.

• FTA portal (starting point): tax.gov.ae — navigate to corporate tax services, publications, and updates relevant to your entity type.
• Guidance lifecycle: After major MoF decisions, the FTA may issue clarifications, user guides, or return-related instructions. Treat these as mandatory reading for operational compliance even when they are not “primary law.”
• Evidence in audits: FTA reviews typically trace amounts in returns to underlying ledgers, contracts, payroll, and project documentation—align R&D evidence packs with that expectation early via documentation systems.

Government policy context (non-binding)

The UAE Government’s official portal summarises innovation-related tax policy themes at u.ae — tax incentives for innovation-driven businesses. Useful for stakeholder communication; always anchor compliance positions to MoF/FTA legal sources.

How to read Cabinet Decision No. 215 of 2025

The Cabinet Decision’s preamble shows the legal instruments it is issued under and cross-references (including the Constitution, Federal Decree-Law No. 28 of 2022 on Tax Procedures, Federal Decree-Law No. 47 of 2022 on Corporate Tax, and Cabinet Decision No. 142 of 2024 on Top-up Tax). Reading the preamble helps you see which concepts are imported by reference.\n+

• Start with definitions: Identify defined terms (often capitalised) and build your glossary before reading operative articles.
• Map exclusions early: Note any explicit exclusions (for example, entity-level exclusions referenced in public commentary such as small business relief elections) and test them against your legal structure chart.
• Trace cross-references: Cabinet decisions frequently point to articles of Federal Decree-Law No. 47 of 2022—open those provisions in parallel.
• Separate policy from mechanics: Where Cabinet Decision No. 215 of 2025 states principles, Ministerial Decision No. 24 of 2026 often carries the numbers—read both together.

How to read Ministerial Decision No. 24 of 2026

Ministerial Decision No. 24 of 2026 also lists instruments it reviewed in its preamble (including the Constitution, Federal Law No. 1 of 1972 on the Competencies of Ministries and Powers of the Ministers, Federal Decree-Law No. 28 of 2022, Federal Decree-Law No. 47 of 2022, Cabinet Decision No. 142 of 2024, and Cabinet Decision No. 215 of 2025). This matters because key definitions used in the Ministerial Decision are imported from those instruments.\n+

• Computation first: Identify sections dealing with tiered rates, caps, average R&D staff, and expenditure categories—these drive models.
• Project rules: Locate thresholds (including any minimum project expenditure) and approval procedures; these are common implementation failure points.
• Staff uplift: If the decision provides an uplift percentage on staff costs, model the base, caps, and exclusions exactly as written.
• Arabic/English consistency: For high-stakes positions, compare Arabic and English where both are official, with professional language support as needed.

If your team needs help translating law into operating procedures, combine this reading plan with team training and claim readiness preparation.

Change control: amendments, clarifications, and translations

Tax regimes evolve. After the initial publication of Cabinet Decision No. 215 of 2025 and Ministerial Decision No. 24 of 2026, watch for amending decisions, FTA clarifications, and return template updates that can change how a rule is applied in practice even when the headline statute text looks unchanged. Maintain a dated changelog for your R&D credit position: which PDF version you relied on, which FTA publication version, and which internal model version produced each number.

Where Arabic and English texts diverge in meaning, follow your governance policy—typically involving bilingual review for material positions—and document the rationale for auditors and advisers. This is especially important for defined terms that interact with payroll law, immigration categories for staff, and free zone regulations.

For enterprise teams, pair legal reading with control design: segregation of duties between project approval, spend booking, and claim sign-off reduces both error risk and fraud risk in incentive regimes with high monetary value.

Quick reference table (where to look)

Operational next steps on randd.ae

Move from legislation to execution: how the credit works, eligibility, and credit amounts. Then engage us across R&D tax services including ongoing advisory.