Our practical view
What the development means
- R&D expenditure may remain deductible under the normal UAE Corporate Tax rules, while eligible businesses may also claim a separate credit against tax payable.
- The Phase 1 credit is non-refundable, applies to periods beginning on or after 1 January 2026 and can reach AED 2 million per qualifying entity per period.
- Only genuine R&D physically performed in the UAE qualifies; routine software work, maintenance and cosmetic upgrades should not be treated automatically as R&D.
UAE R&D Tax Credit rates
| Qualifying expenditure band | Credit rate | Average R&D staff | Maximum credit |
|---|---|---|---|
| First AED 1 million | 15% | At least 2 | AED 150,000 |
| Above AED 1m to AED 2m | 35% | At least 6 | AED 350,000 |
| Above AED 2m to AED 5m | 50% | At least 14 | AED 1,500,000 |
Maximum credit: AED 2 million per qualifying entity per Tax Period or Fiscal Year, subject to all eligibility requirements.
How R&D expenses are deducted under UAE Corporate Tax
The starting point for UAE Corporate Tax is the accounting profit or loss shown in the financial statements. Research and development expenditure is generally deductible when it is incurred wholly and exclusively for the taxable business, is not connected with exempt income and is not restricted by another provision of the Corporate Tax Law.
Research costs expensed in the statement of profit or loss will ordinarily be deducted in that Tax Period. Development expenditure capitalised as an intangible asset generally affects taxable income through the accounting amortisation or impairment charge, subject to the Corporate Tax rules. The new incentive is a tax credit rather than a 150% or similar enhanced deduction.
What is a qualifying R&D activity?
A project must seek to increase knowledge or develop a new application and display the recognised R&D characteristics of novelty, creativity, uncertainty, a systematic process, and results capable of being reproduced or transferred.
- Experimental development of a genuinely new AI model, algorithm, process or technical capability may qualify.
- Work that resolves a documented scientific or technological uncertainty may qualify.
- Routine coding, ordinary SaaS configuration, bug fixing, maintenance, market research and cosmetic product changes will generally not qualify merely because they are described internally as innovation.
- The qualifying activities must be physically performed in the UAE. Overseas development activity does not qualify even if it is funded or managed by a UAE company.
Which R&D costs may qualify?
Costs funded by relevant government grants, costs already benefiting from another UAE tax incentive and specified intra-Tax Group recharges are excluded. Each R&D project must meet a minimum qualifying expenditure threshold of AED 500,000.
- Eligible R&D staff costs, together with the prescribed 30% staff-cost uplift for overheads.
- Consumables used for the qualifying R&D activities.
- Fees paid to a UAE subcontractor where the underlying R&D is undertaken in the UAE.
- Arm’s-length contributions under qualifying cost-contribution arrangements.
- Eligible costs capitalised under the applicable accounting standards as part of an internally generated intangible asset.
How the non-refundable credit works
The credit is first applied against UAE Corporate Tax and, where applicable, Domestic Minimum Top-up Tax. It does not create a cash refund when it exceeds the current liability. Subject to continuity and other conditions, an unused balance may be carried forward indefinitely and, in limited cases, transferred to a commonly owned taxable juridical person.
For example, an eligible company with AED 3 million of qualifying expenditure and at least 14 average R&D staff could generate a credit of AED 1 million: AED 150,000 on the first AED 1 million, AED 350,000 on the next AED 1 million and AED 500,000 on the third AED 1 million. If its Corporate Tax liability is AED 600,000, the liability could be reduced to nil and AED 400,000 carried forward, subject to all conditions.
Special consideration for Qualifying Free Zone Persons
A Qualifying Free Zone Person should not assume that the credit can be used against income taxed at 0%. Under the R&D credit conditions, the relevant R&D income generally needs to be subject to 9% Corporate Tax or UAE Top-up Tax. A Free Zone IP or R&D structure therefore requires modelling of both the qualifying-income rules and the practical usability of the credit.
Pre-approval and documentation
A claim requires approval from the competent authority and strong contemporaneous evidence. The claimant must bear the financial risk of the project and be beneficially entitled to the economic returns from its results.
- Approved project plan and technical objective.
- Evidence of novelty and the uncertainty being resolved.
- Names, roles, time records and UAE location of R&D personnel.
- Project-wise general-ledger mapping and supporting invoices.
- Subcontractor scope, location and arm’s-length support.
- Accounting treatment of expensed and capitalised development costs.
- Records supporting the claim retained for at least seven years.
Recommended actions
What UAE businesses should do now
- Identify each R&D project and document its scientific or technological objective and uncertainty.
- Create project-specific cost codes for staff, consumables, subcontractors and capitalised development costs.
- Test the AED 500,000 project threshold and the applicable average R&D employee threshold.
- Seek the required pre-approval before claiming and retain technical and financial evidence for seven years.
- Model whether a Free Zone structure will produce usable credit, particularly where relevant income is subject to the 0% QFZP rate.
Frequently asked questions
Is UAE R&D expenditure fully deductible?
It is generally deductible when incurred wholly and exclusively for the taxable business and not restricted under the Corporate Tax Law. Immediate deduction or deduction through amortisation depends principally on the applicable accounting treatment.
What is the maximum UAE R&D Tax Credit?
The maximum Phase 1 credit is AED 2 million per qualifying entity per Tax Period or Fiscal Year, subject to the expenditure bands, average R&D staff thresholds and all other conditions.
Does software development qualify for the UAE R&D Tax Credit?
It can qualify where the work is novel, systematic and resolves genuine technological uncertainty. Routine coding, configuration, maintenance, bug fixing and cosmetic enhancements generally do not qualify by themselves.
Can a UAE Free Zone company claim the R&D credit?
Potentially, but a Qualifying Free Zone Person must satisfy additional conditions. In particular, relevant R&D-derived income generally needs to be subject to 9% Corporate Tax or UAE Top-up Tax rather than the 0% QFZP rate.
Is the UAE R&D Tax Credit refundable?
No. Phase 1 is non-refundable. Unused credit may be carried forward indefinitely, subject to the prescribed continuity and compliance conditions.
Always refer to the full source text and its effective-date and transitional provisions.
UAE Ministry of Finance — Phase 1 R&D Tax Incentives ProgrammeThis article provides general information and does not constitute tax advice. Eligibility and treatment should be assessed against the enacted legislation and the facts of each case.
