Dubai Science Park in 2026: Pharma, Biotech and Medtech — the DDA Licence, EDE Registration and DHA Licensing

Dubai Science Park is one of the ten districts for which the Dubai Development Authority (DDA) issues licences under its Decision No. 1 of 2021, and one of the ten districts TECOM Group calls its own — two lists of ten that do not coincide. A DDA licence opens the door to life sciences activity but confers no right either to sell medicines and medical devices or to treat patients: the product layer belongs to the federal Emirates Drug Establishment (EDE), and patient-facing services to the Dubai Health Authority (DHA). All three licences run in parallel, and none substitutes for another.

Three points that determine the economics of a Dubai Science Park project.

First: Dubai Science Park is not a Designated Zone for VAT purposes. The Federal Tax Authority’s published list names nine Dubai zones, seven of them still live; Dubai Science Park is not among them. The corporate tax consequence: the qualifying activity “distribution of goods or materials in or from a Designated Zone” is unavailable to a Dubai Science Park company, while manufacturing and processing are available with no Designated Zone condition at all.

Second: research and development is not a qualifying activity. Article 2(1) of Ministerial Decision No. 229 of 2025 lists fourteen of them, and R&D is not one. Income from research services supplied to a person outside the free zones is not qualifying income.

Third: the R&D tax credit and the 0% corporate tax rate are mutually exclusive. Article 3(2) of Cabinet Decision No. 215 of 2025 admits a Qualifying Free Zone Person to the credit only where it is taxed at 9% on taxable income derived from the qualifying R&D activities, or is within scope of the Top-up Tax. A company on 0% gets no credit — and becoming a Qualifying Free Zone Person within five years of the last claim triggers a claw-back of everything already used.

The Legal Base: Three Regulatory Layers That Must Not Be Conflated

A Dubai Science Park company sits simultaneously under three independent regimes: the zone regime (DDA), the federal product regime (EDE) and the emirate health regime (DHA). Each has its own instrument, its own regulator and its own sanction, and none absorbs the others.

Layer	Instrument	Key dates	Regulator	What it governs
Emirate — the zone	Dubai Law No. 15 of 2014(issued 27 October 2014), as amended by Law No. 8 of 2023(issued 6 February 2023)	Law No. 8 of 2023 came into force on the day of issue	Dubai Development Authority	Free zone status, boundaries, the DDA’s powers
Zone subordinate	DDA Decision No. 1 of 2021 Concerning Licence Categories	Bears no day or month of issue; replaced Decision No. 1 of 2018	DDA	The list of districts, segments, activities, fees, capital
Company forms	Dubai Creative Clusters Private Companies Regulations 2016	—	DDA as Registrar	FZ-LLC, branches, shareholders, capital
Federal — products	Federal Decree-Law No. 38 of 2024 Governing Medical Products, Pharmacists and Pha­rmaceu­tical Esta­bli­shments	Issued 1 October 2024; in force 2 January 2025; Official Gazette No. 785 of 14 October 2024	Emirates Drug Esta­blishme­nt	Product registration, licensing of pha­rmaceu­tical esta­blishme­nts, pricing, import
Federal — the regulator	Federal Decree-Law No. 28 of 2023 establishing the Emirates Drug Establishment	Issued 25 September 2023; in force 30 September 2023; Official Gazette No. 760	Cabinet	Creation and powers of the EDE
Emirate — health	Dubai Law No. 6 of 2018concerning the Dubai Health Authority	Issued 30 April 2018, in force on the day of issue	Dubai Health Authority	Healthcare facilities and pro­fessio­nals, free zones included
Emirate subordinate	Executive Council Resolution No. 49 of 2024	Issued 28 August 2024; in force 60 days after publication; superseded Resolution No. 32 of 2012	DHA	Licensing of health activities and professions
Operating onshore	Executive Council Resolution No. 11 of 2025	Issued 3 March 2025, in force on publication	Department of Economy and Tourism	A free zone company’s right to operate onshore in Dubai

Federal Law No. 8 of 2019 has been repealed. Article 180 of Decree-Law No. 38 of 2024: “The aforementioned Federal Law No. (8) of 2019 is hereby repealed, as well as any provision that violates or contradicts the provisions of this Decree-Law.” Paragraph 2 of the same article preserves the subordinate instruments made under the repealed law “until regulations and resolutions have been issued to replace them”.

Note that no Executive Regulation to Decree-Law No. 38 of 2024 had been issued as at August 2026. It appears neither on the UAE legislation portal nor on the Emirates Drug Establishment’s own legislation page, and the EDE’s live service page for medical warehouse licensing still directs applicants to “Circular No. 90 of 2021 of Federal Law No. 8 of 2019” — an instrument of 2021 made under the repealed 2019 law; the page itself calls it neither a Cabinet Resolution nor an Executive Regulation. The practical consequence: the detailed requirements for pharmaceutical establishments in 2026 still come from the 2021 regulation, which survives by force of article 180(2).

Two of the governing instruments expressly disclaim exclusivity, and that shapes the entire structure. Article 2.15 of DDA Decision No. 1 of 2021: “The issuance of a Licence by the Authority does not exempt the Licensee from having to obtain any other permit, licence or approval from such other regulators as required by Dubai or UAE law in the conduct of business.” Article 173 of Decree-Law No. 38 of 2024: “Obtaining the Licenses stipulated in this Decree-Law does not exempt from obtaining other licenses required by the laws, regulations or systems in force in the State.” Neither the zone licence nor the federal licence stands in for the other.

What Dubai Science Park Is, and Which Instrument Names It

Dubai Science Park is named in a subordinate instrument of the Dubai Development Authority, but in no law or decree of the emirate. That is not a gap in the research but a feature of the design: the emirate legislates for the zone by reference to the DDA, to “the Creative Clusters” and to numbered land plots, not by district name.

The definition in DDA Decision No. 1 of 2021 reads: ‘“DSP” means the Dubai Science Park.’ The same article defines the set of districts: ‘“BU” means the business parks located within the Zone which includes DMC, DIC, DKP, DOC, DSC, DSP, DPC, DIAC, ET and D3.’ And the cluster concept: ‘“Cluster” means the different sectors within the Zone in which businesses share the same or a related product or service which includes Science, Media, ICT, Design and Education.’

The two lists of ten do not coincide, and that matters when choosing a location. The ten districts of Decision No. 1 of 2021 include Emirates Towers but not Dubai Industrial City. The ten districts that TECOM Group and the DDA itself describe as the Group’s business districts include Dubai Industrial City and not Emirates Towers. The practical consequence: a district’s membership of TECOM Group does not mean that Decision No. 1 of 2021 gives it segments and tariffs of its own.

The Decision’s own heading lists all ten of its districts, with Dubai Science Park eighth: “Concerning Licence Categories for Dubai Internet City, Dubai Media City, Dubai Knowledge Park, Dubai International Academic City, Dubai Outsource City, Dubai Production City, Dubai Studio City, Dubai Science Park, Dubai Design District and Emirates Towers.”

Neither Law No. 15 of 2014 nor Law No. 8 of 2023 names any district at all. The operative text of article 3 of Law No. 15 of 2014 is the one substituted by article 1 of Law No. 8 of 2023: “This Law applies to: 1. the DDA…; 2. the Creative Clusters, and the land plots, whose boundaries and areas are demarcated on the plans attached to this Law and which constitute a free zone governed by the legislation applicable to the DDA, including the above-mentioned Decree No. (30) of 2017; and 3. any other zone or land plot that becomes subject to supervision by the DDA pursuant to a resolution issued by the Ruler, upon the recommendation of the Chairman.” The schedule to Law No. 8 of 2023 is a list of twenty-four cadastral plots in the form “Plot No. (5), Al Sufouh 2” and “Plot No. 2, Al Me’aisam 1”. Not one district is mentioned by name.

The earlier wording of article 3, which declared a free zone of “The Creative Clusters, whose boundaries, area, and locations are demarcated on the map attached to this Law”, was substituted by article 1 of Law No. 8 of 2023 and is not operative. The current text adds a third limb that did not exist before: any other zone or plot may be brought under DDA supervision by a resolution of the Ruler. The practical consequence: the territory under the DDA can change without any change to the law.

Contrast the neighbouring district of the same operator: Dubai Industrial City is, conversely, absent from the ten districts listed in Decision No. 1 of 2021. That case is examined separately in our analysis of Dubai Industrial City. The practical consequence: a district’s affiliation to the DDA and its legal identification are two different questions, and each must be checked against the specific instrument rather than against a general impression of TECOM Group.

Dubai Science Park is the only one of the ten districts allotted two Parts in the Decision. The activity schedules are organised into eleven Parts, and Part Eight and Part Nine are both headed “DUBAI SCIENCE PARK”: the first carries Segment 23 (life sciences), the second Segment 24 (energy and environment). It is the legacy of a merger of two earlier districts — Dubai Biotechnology and Research Park and Energy and Environment Park — which DDA Decision No. 1 of 2014 still listed separately. The exact date of the merger could not be established from primary sources.

Neither Law No. 15 of 2014 nor Law No. 8 of 2023 has been amended since 2023. The Dubai legislation portal’s “Free Zone and Special Development Zone Affairs” category contains instruments from 2024 and 2025, none of which touches Law No. 15 of 2014, and none at all from 2026. DDA Decision No. 1 of 2021 has likewise not been replaced — the DDA’s “Laws & Regulations” page carries a single licence-categories instrument, and its archive of superseded regulations contains nothing later than a 2018 circular. Articles 1.7 and 1.8 of the Decision do, however, reserve to the Director General the power to issue and amend guidelines, policies and circulars, and the DDA maintains a separate circulars register on its own page, which is outside the scope of this article.

The author’s assessment: the absence of the district’s name from the emirate’s laws is not a formality but a live risk in tax planning. “Free Zone” is defined in Federal Decree-Law No. 47 of 2022 as “a designated and defined geographic area within the State that is specified in a decision issued by the Cabinet at the suggestion of the Minister”. No publicly issued Cabinet decision listing free zones for corporate tax purposes could be located, and the Federal Tax Authority’s guidance passes the question back to the zone itself: “All taxpayers should check with their respective Free Zone Authority to confirm if they operate in a Free Zone or Designated Zone for Corporate Tax purposes.” The practical consequence: obtain written confirmation of status from the DDA before incorporating, not after the first tax return.

Who Issues the Licence: the DDA, Not TECOM Group

Licences in Dubai Science Park are issued by the Dubai Development Authority; TECOM Group is the operator and landlord. The DDA states the division on its own page: “The Group’s business districts are located and operated under the jurisdiction of Dubai Development Authority (DDA), which is in charge of company registration and licensing, employee services, planning and development as well as developing and implementing regulations.”

A terminological point: within the Decision itself, “Authority” is defined as the Dubai Creative Clusters Authority. Article 1.1: ‘“Authority” means the Dubai Creative Clusters Authority.’ The phrase “Dubai Development Authority” appears once in the document’s 136 pages, although the Decision is signed by the DDA’s Director General. The reason lies in the chain of renamings: Law No. 10 of 2018 changed the names within the Dubai Creative Clusters Authority, and Law No. 8 of 2023 substituted article 3 of Law No. 15 of 2014. The practical consequence: quotations of the Decision referring to “the Authority” should be read as referring to the DDA; the difference in name does not indicate a different body.

Article 2.1 of Decision No. 1 of 2021 names the districts for which the DDA issues licences: “Licences are issued by the Authority for each of DIC, DMC, DKP, DIAC, DPC, DOC, DSC, DSP and D3 for their respective licence segments as set out below. Licences for ET may be issued for any of the licence segments.” The same TECOM regulatory architecture is examined for neighbouring districts in our analyses of Dubai Internet City and Dubai Media City.

Which Company Forms Are Available

The operator names three forms: an FZ-LLC, a branch of an existing company, and a freelance permit — “New incorporation of a Free Zone Limited Liability Company (FZ-LLC) • Branch of an existing foreign/UAE company • Freelance permit.”

On the text of Decision No. 1 of 2021 no freelance permit is issued in Dubai Science Park, and this divergence between the instrument and the operator’s materials should be resolved in favour of the instrument. Article 2.9 confines the freelancer segments to four: “Segment 16.5, Segment 18.9, Segment 21.13 and Segment 25.10” — segments of Dubai Internet City, Dubai Media City, Dubai Knowledge Park and Dubai Design District. There is no freelancer segment in Segments 23 or 24, and the article 14 fee table for Dubai Science Park contains no Freelancer row — unlike the DIC, DMC, DKP and D3 tables, where it appears at AED 7,500. The practical consequence: an intention to work in Dubai Science Park as a freelancer needs express written confirmation from the DDA before any lease is signed.

Decision No. 1 of 2021 itself sets out no menu of forms and refers instead to the 2016 Private Companies Regulations. Its definition: ‘“PCR” means the Dubai Creative Clusters Private Companies Regulations 2016.’ The key provisions of those Regulations:

Provision of the 2016 Regulations	Substance
Regulation 8.1	“Any one or more persons and no more than 75 (or such lesser number as the Registrar may, in its discretion, determine) may apply to form a company with limited liability”
Regulation 8.2	Separate legal personality; members’ liability limited to the amount unpaid on their shares
Regulation 12.3.1	The name must end with the word “FZ-LLC”
Regulation 25.1	“The minimum issued fully paid up share capital of a company shall be such amount as the Registrar specifies from time to time”
Regulation 25.2	Shares in a currency other than the dirham only with the Registrar’s consent
Regulation 25.3	Subject to Regulation 27 — a single class of shares of equal nominal value carrying identical rights
Regulation 90.1	A foreign company may carry on business in the zone only if registered as a branch or issued a certificate of continuation

Note that there is no FZ-CO in Dubai Science Park. The string “FZ-CO” does not appear once in the 136 pages of Decision No. 1 of 2021, and the operator does not list it among the available forms. The practical consequence: a public company cannot be formed in Dubai Science Park. On multiple share classes there is no prohibition: Regulation 25.3 operates “subject to Regulation 27”, and Regulation 27.1 allows the Registrar to “consent to a company dividing its share capital into different classes of shares or to a company issuing new shares of a different class”. Multiple classes are possible, but only with the Registrar’s consent — which should be obtained before, not after, a transaction is structured.

Obligations the Licence Creates Immediately

Every licensee must keep full details of its ultimate beneficial ownership at its registered office. Article 2.11: “Every Licensee shall maintain at its Registered Office full details of the Ultimate Beneficial Ownership (‘UBO’) of the Licensee… The Licensee shall supply the UBO to the Authority on demand by the Authority.” Failure to supply on demand attracts a fine of AED 5,000 under item 6 of Schedule 4, which adds that the regulator “may additionally or alternatively apply the sanctions set out in Article 10 of the Licensing Regulations”. Note an internal inaccuracy in the instrument: item 6 of Schedule 4 refers to a breach of “Article 2.10”, whereas the beneficial ownership duty sits in article 2.11; article 2.10 concerns Segment 27 permits.

Every licensee must prepare and retain audited accounts. Article 2.8: “Each Licensee must prepare and retain Audited Accounts. A Licensee shall supply its Audited Accounts to the Authority on demand by the Authority.”

Licences run for one year and are renewed annually. The minimum lease term is likewise one year. The operator states the registration timeline as “it usually takes 7 working days” — four working days for initial approval and three for issuance of the licence.

The Customs Code: Three Options and One Consequence

Article 3.6 offers the licensee a choice of three, and it determines whether the company can import at all. It reads: “Licensees have the option to choose one of the following: i) to obtain a free zone customs code issued by Dubai Customs which will allow import and re-export from the Zone; however, the goods/products shall be stored within the Zone bounded area; or ii) request a local customs code; however, the Licensee must pay the appropriate customs duty upon arrival of the goods/products; or iii) not obtain a customs code, which will mean the Licensee may not import any goods/products.”

The practical consequence for a pharmaceutical distributor: option (i) requires the goods to be stored within the bounded area of the zone. Stock destined for the mainland cannot be shipped directly under option (i) without going through customs. The clearance and import VAT mechanics are covered separately in our analysis of UAE import, customs and import VAT.

Segments and Activities: What Is Actually Licensed

Decision No. 1 of 2021 licenses segments and the activities inside them, not “licence types”. The familiar mainland Dubai triad of commercial, service and industrial licences is absent from the text entirely: the strings “commercial licence”, “service licence”, “industrial licence” and “trade licence” do not appear once in the document.

Article 3.1 sets out the structure: “Each of DIC, DMC, DKP, DIAC, DPC, DOC, DSC, DSP and D3’s licence categories are divided into segments and a number of activities may be carried out under each segment.”

Segment 23: Life Sciences

Part Eight contains ten segments, and this is the working catalogue for a pharmaceutical, biotech or medtech company.

Segment	Official name and definition
23.1	The­rapeu­tics — “Organi­zations/Co­mpanies dealing with products used to treat and/or prevent conditions affecting humans”
23.2	Food
23.3	Agri­cultu­ral, Horticulture and Agriculture Technology
23.4	Envi­ronme­nt
23.5	Medi­cal/Scie­ntific Devices or Equipment — “Organi­zations/Co­mpanies dealing with medical and/or scientific devices and/or equipment, including related consumables”
23.6	Specialty Supplies — “Organi­zations/co­mpanies dealing with specialized products having a medical and/or scientific application”
23.7	Diagnostics and Analysis — “Organi­zations/co­mpanies performing testing and/or analysis services”
23.8	Life Science Services — “Organi­zations/co­mpanies providing specialized services for the life science sector”
23.9	Life Science Associations (No­n-Pro­fit)
23.10	Conformity Assessment and Certification Agency

Segments 23.1 to 23.6 are each divided into the same six activities: Research & Development; Storage; Marketing and Sales Promotion; Manufacturing and Production; Import and Re-Export; Support Service. Segment 23.5 adds a seventh — Service Centre.

Segment 23.7 is built differently, with four activities: Screening & Testing (“Activities related to processing, analysing, screening and testing of samples”), Research & Development, Marketing & Sales Promotion and Support Service.

Segment 23.8 contains an activity that is often sought and rarely found: regulatory affairs. Activity 23.8.5, “General Professional Services”, is described as “Activities involved in providing regulatory affairs services, architectural design and fit-out, economic and financial services, selection & recruitment, planning, legal advice, market research and analysis, data management and analysis, IT services etc. related to Life Science and Healthcare.”

A terminological warning that matters on application: the words “biotech”, “medtech” and “pharma” do not appear among the segment names. “Biotechnology” appears once in the Decision, inside the description of segment 23.10 (“Food biotechnology”). A biotech company licenses through Therapeutics (23.1), Diagnostics and Analysis (23.7) or Life Science Services (23.8); medtech through Medical/Scientific Devices or Equipment (23.5); a pharmaceutical company through Therapeutics (23.1). A wrong segment chosen at the outset can only be corrected by adding a segment for a further fee.

Segment 24: Energy and Environment

Part Nine, also headed “Dubai Science Park”, carries ten segments: 24.1 Renewable Energy; 24.2 Energy; 24.3 Energy Efficiency Equipment; 24.4 Air and Environment; 24.5 Water and Waste Water; 24.6 Recycling and Solid Waste; 24.7 Transportation; 24.8 Green Building; 24.9 Organic Products; 24.10 Association (Non-Profit Organisations). Each is defined in Part Nine itself, not merely in the fee table.

The activity sets across segment 24 are not uniform. Segments 24.1 to 24.7 are divided into Consultancy, Management, Research and Development, Marketing, Storage, Testing and Manufacturing; segment 24.8 Green Building carries only Consultancy, Management, Research and Development, Manufacturing and Storage — no Marketing, no Testing; segment 24.9 Organic Products has no Testing; and segment 24.10 is built differently, its sub-items listing industries rather than activities.

Note the mismatch between the number of activities in a segment and the cap in the fee table. Segments 24.1 to 24.7 define six non-manufacturing activities, while the article 14 table allows five per non-manufacturing entry. The practical consequence: a segment 24 licensee must choose five of the six, and the choice deserves to be made deliberately rather than by default.

General Segment 26 is available in every district. Article 2.2: “Licences for activities under the General Segment are issued by the Authority for all BU.” It is through this route that a Dubai Science Park company can take an activity such as “Medical Laboratory” — with the consequences examined below.

Freelancers are licensed separately, and not in every district. Article 2.9: “Natural persons are licensed by the Authority to operate as Freelancers under the Freelancer Segments (Segment 16.5, Segment 18.9, Segment 21.13 and Segment 25.10)” — segments 23 and 24 are not among them. A freelance permit costs AED 7,500 a year under article 9.2, but no corresponding row appears in the Dubai Science Park fee table.

What the Licence Costs, and How Many Activities It Buys

The annual segment fee in Dubai Science Park is AED 15,000 for non-manufacturing segments and AED 25,000 for manufacturing ones. The price difference is not the point: a non-manufacturing segment carries five activities, a manufacturing segment one.

Segment	Annual fee	Activities allowed in the segment
The­rapeu­tics (except Manufacturing and Production)	AED 15,000	five
The­rapeu­tics — Manufacturing and Production	AED 25,000	one
Medi­cal/Scie­ntific Devices or Equipment (except Manufacturing and Production)	AED 15,000	five
Medi­cal/Scie­ntific Devices or Equipment — Manufacturing and Production	AED 25,000	one
Specialty Supplies (except Manufacturing and Production)	AED 15,000	five
Specialty Supplies — Manufacturing and Production	AED 25,000	one
Food / Agri­cultu­ral, Forestry, Horti­cultu­re / Envi­ronme­nt — same pattern	AED 15,000 / AED 25,000	five / one
(Part Eight names the same segment “Agri­cultu­ral, Horticulture and Agriculture Technology” — a naming divergence within the Decision itself)
Diagnostics and Analysis	AED 15,000	four
Life Science Services	AED 15,000	five
Life Science Associations (No­n-Pro­fit)	AED 15,000	one
Conformity Assessment and Certification Agency	AED 15,000	one
Segment 24 (energy and environment), except Manufacturing	AED 15,000	five
Segment 24 — Manufacturing	AED 25,000	one
Freelance permit — absent from the Dubai Science Park table; the AED 7,500 fee under art. 9.2 applies to the districts where a freelancer segment exists	—	—

A structural consequence that is routinely underestimated: a manufacturing segment is single-activity by definition. A manufacturer that also wants to market, store and import must buy further segments. Article 10.1 prices an additional segment at AED 10,000 on top of the fee for the current segment, “provided that such Additional Segment is a standard segment charged at an annual licence fee of AED15,000. Where the Additional Segment selected is charged at a higher annual licence fee than AED15,000, then no discount will apply.” The practical consequence: a “manufacture plus market plus import” combination costs not AED 25,000 but AED 25,000 plus additional segments.

Adding activities within one segment is free. Article 10.4: “A Licensee may, subject to the per-segment limits set out in Article 14 below, add additional activities to its Licence from the same segment for no additional Licence fee.”

Adding an activity from another cluster is a matter for the regulator’s discretion. Article 11.1: “A Licensee licensed in one Cluster may add an additional segment or activity from another Cluster at the sole discretion of the Authority.”

The author’s assessment: the Dubai Science Park tariff is built so that the cheapest model is non-manufacturing with a wide activity set, and the most expensive is full-cycle manufacturing. Five activities at AED 15,000 against one at AED 25,000 is a ratio of 1:8 per activity. The practical consequence: where manufacturing is contracted out and the company itself develops, registers, markets and imports, the licensing burden is several times lower — and that model also sits better with the tax structure examined below.

The choice of activity has consequences well beyond the licence fee. It determines which external approvals will be required, how the bank account is opened, and how the business is treated for VAT and customs — mechanics covered separately in our analysis of UAE trade licence activities.

Share Capital: Why AED 10,000, Not AED 25,000

The minimum paid-up share capital of an FZ-LLC in Dubai Science Park is AED 10,000. That is the residual rule in article 15.1 of Decision No. 1 of 2021, and it applies to Dubai Science Park in full, because the district has no capital table of its own.

Article 15.1 reads: “Subject to certain minimum paid up capital amounts set out below for specific segments and activities, for all other activities and for the purposes of Regulation 25.1 of the PCR, the minimum paid up capital of an FZ-LLC shall be AED 10,000. The following segments and activities shall have the minimum paid up capital as set out against each.”

The tables that follow article 15.1 are headed DOC, DPC, DSC, DIAC, D3 and General Segment. There is no DSP table among them.

The direct consequence: a Dubai Science Park company taking activities only from segments 23 and 24 capitalises at AED 10,000. Higher requirements arise only where an activity is taken from the General Segment, for which a table does exist: Support Services (other than the listed exceptions) — AED 50,000; Support Services in respect of a General Hospital, Ambulatory Care Facility, Poly Clinic, Theatre and Cinema and Shopping Centre/Mall — AED 500,000; Regional Head Quarters — AED 50,000; Property Management Services — AED 50,000. The same table carries hotel entries with thresholds from AED 1,000,000 to AED 3,000,000, none of them relevant to life sciences.

A Common Error: AED 25,000 and AED 15,000 Are Not Capital

The figures AED 25,000 and AED 15,000, often quoted as capital requirements for manufacturing and non-manufacturing companies in Dubai Science Park, are not capital at all. They are the annual licence fees from the article 14 table set out in the previous section. Article 15 contains no Dubai Science Park capital table whatsoever.

The manufacturing / non-manufacturing split in Dubai Science Park is about the number of activities in a segment, not about capital — five against one, as shown above.

Article 15 contains no shareholder rules. Those sit in the 2016 Private Companies Regulations: up to 75 members (Regulation 8.1) and a single class of shares of equal nominal value (Regulation 25.3).

The author’s assessment: the capital figure creates no practical barrier in Dubai Science Park, and a structure should not be planned around it. AED 10,000 is symbolic; the real entry cost is driven by the rent on laboratory or warehouse space, by licence fees across however many segments are needed and, for a product business, by the cost of federal registration with the Emirates Drug Establishment. The practical consequence: comparing Dubai Science Park with other zones on capital is pointless — the comparison that matters is the availability of the right segment, Designated Zone status, and whether suitable premises exist.

A comparison with neighbouring districts of the same operator shows AED 10,000 to be a DDA-wide figure rather than a Dubai Science Park peculiarity. The same residual rule is analysed in our pieces on Dubai Media City and Dubai Design District.

Premises: Laboratories, Warehouses and Light Industrial Units

Dubai Science Park offers three types of premises for life sciences: the Laboratory Complex, storage and logistics space, and light industrial units. All three are described on the district’s official pages, each with published technical parameters.

The Laboratory Complex is let shell and core. The district’s own description: “Our LEED-certified Laboratory Complex in Dubai Science Park is built to the highest global standards, designed to support businesses in the science sector, including research, product development, testing, diagnostics, manufacturing, and production… The shell and core spaces are equipped with advanced systems, including air exhaust and ventilation, acid-resistant drainage, and a pH neutralization system… With a LEED Silver Certification, the Laboratory Complex is committed to environmentally responsible practices.”

Dubai Science Park measure	Figure	Source and date
La­bora­tories in the district	over 90	district press release, 5 February 2026
Pro­fessio­nals in the district	more than 6,500	TECOM Group release of 5 June 2024 and district release of 5 February 2026 — the figure is unchanged over two years
Gross leasable storage area	more than 330,000 sq ft	district press release, 5 February 2026
Target storage area under the expansion project	336,000 sq ft	TECOM Group press release, 5 June 2024
Increase in storage capacity under the expansion	147%, adding 200,000 sq ft	TECOM Group press release, 5 June 2024
New storage units	26, ranging from 6,000 to 16,000 sq ft	TECOM Group press release, 5 June 2024
Warehouses: size range	6,400 to 16,800 sq ft	Dubai Science Park storage and logistics page
Warehouse power	129 to 351 kW	storage and logistics page
Warehouse height	12 m eaves	storage and logistics page
Light industrial units	5,000 to 6,000 sq ft	light industrial units page
Customers in the district	more than 500	TECOM Group press release, 5 June 2024
TECOM Group commercial and industrial occupancy	97% in 2025	TECOM Group PJSC results, 3 February 2026
TECOM Group customers overall	more than 12,200 at 31 December 2025	TECOM Group PJSC results, 3 February 2026

Note two divergences among the official figures. The first concerns headcount: “more than 6,500” is repeated unchanged from June 2024 to February 2026, while the district’s own retail page gives “3600+ professionals”. The second concerns storage area.

On the storage area. The June 2024 release gave a target of 336,000 sq ft on completion of an expansion “due for completion next year”; the February 2026 release refers to “more than 330,000 sq.ft.”. No completion announcement could be found in official sources. Both figures are given here with their dates rather than reconciled into one.

The warehouses are expressly intended for pharmaceuticals and medical devices. The district’s description: “We have warehouses specifically designed to accommodate application industries such as pharmaceuticals, medical devices/equipment’s, conventional renewable energy, environmental products, chemicals/flavours and fragrances, green building, agriculture, air and water management.” On suitability: “Apt for light manufacturing, logistics & storage (cold, chemical & general).”

What the official sources do not contain, and what should therefore not be asserted. The words “GMP”, “Good Manufacturing Practice”, “cleanroom” and “ISO class” appear on no official Dubai Science Park or TECOM Group page. There is no basis for stating that the district offers GMP-ready space. Equally unpublished are the Laboratory Complex’s floor area, its number of units, and any warehouse temperature specification: the only official wording on cold storage is “cold, chemical & general” in the suitability list. Whether premises meet GMP or cold-chain requirements is a matter for the tenant’s fit-out, not a characteristic of the building.

The district names its own occupiers. Its twentieth-anniversary release of 5 February 2026 lists AstraZeneca, Pfizer, Boston Scientific, Himalaya Wellness and ThermoFisher Scientific; it notes that Jotun “operates a R&D laboratory from its regional headquarters at Dubai Science Park”, that DSM-Firmenich runs a “Creation & Development Centre”, and that IFF opened its “Scent Dubai Creative Centre” in 2025. The June 2024 release additionally names Epygen Labs, which “operates a laboratory for industrial enzymes”, and Elixir Pharma, which “has a secondary packing and batch release site”.

The author’s assessment: “secondary packing and batch release site” is the most concrete published indication of the district’s actual manufacturing profile. Secondary packing and batch release are the closing operations of a pharmaceutical cycle, not active-substance synthesis. The practical consequence: on its published materials Dubai Science Park positions itself as a base for R&D, diagnostics, secondary packing, storage and logistics — not for primary pharmaceutical manufacture.

Visas and the Establishment Card: One Visa per 80 Square Feet

The only visa rule specific to Dubai Science Park is a space-to-visa ratio: one visa per 80 square feet of leased space. The district’s wording: “Yes, to ensure a safe and proper working environment, a company can sponsor one employee per 80 sq. ft. of the leased space.”

DDA Decision No. 1 of 2021 does contain visa provisions, but they attach to the hotel segment rather than to the life-sciences segments. Article Seven of Schedule 2, “Employment and Tourist Visas”, gives the owner of a hotel property a maximum of fifteen employment visas (paragraph 7.2) and a quota table, “Employment Visa Quota (Staff per room) 1.65 / 1.2 / 0.8 / 0.75” (paragraph 7.3), while paragraph 7.7 provides for the regulator to assist in obtaining an immigration card from the General Directorate of Residency and Foreigners Affairs (GDRFA). Schedule 1 carries preferential visa terms including “Reduced Visa cost of AED 1,500 per Visa” and “Zero deposit requirement for Visa”. For segments 23 and 24 the Decision sets no visa rules of its own, and the one-visa-per-80-square-feet ratio remains a leasing and services rule of the operator.

The federal employment frame is Federal Decree-Law No. 33 of 2021 on the regulation of employment relations.Work permits and residence visas for the employees of a free zone company are processed through the zone authority, with the visa itself issued by the General Directorate of Residency and Foreigners Affairs. No published instrument setting a visa quota for segments 23 and 24 of Dubai Science Park could be located: the only published benchmark is the operator’s one-visa-per-80-square-feet rule.

The establishment card is issued by the General Directorate of Residency and Foreigners Affairs in Dubai. The official fees for the “Establishment Card for Institutions in the Private Sector/ Free Zone” service:

Fee component	Amount
Issuing an establishment card	AED 200 plus 5% VAT
Knowledge Dirham	AED 10
Innovation Dirham	AED 10
Service fee	AED 50
Urgent processing	AED 100
Submission through Amer centres — additional	AED 100
Issuance or renewal	AED 100 per year

The published expected completion time for the service is 48 hours.

Documents required, per the official service description: “1. A copy of the appendix of the names of the partners. 2. Passport copies of the authorised signatories. 3. A copy of the authorisation certified by the notary public for the authorised persons (in the case of a manager).”

The operational layer runs on the axs platform. In the district’s description it delivers “visa, leasing and other setup services under one roof”, across “more than 200 government and corporate solutions”.

A practical detail worth planning around: there is no axs service centre inside Dubai Science Park. The three physical centres are in Dubai Knowledge Park, Dubai International Academic City and Dubai Studio City. The practical consequence: in-person visits on visa and registration matters are made to other TECOM Group districts.

Employee medical insurance is mandatory in Dubai and must be in place before a residence visa is issued. The requirement flows from the emirate’s health insurance legislation and is covered separately in our analysis of employee health insurance in the UAE. For a Dubai Science Park company this is the second point of contact with the Dubai Health Authority — the first being licensing of health activities, where any are carried on.

The author’s assessment: the 80-square-foot rule makes visa capacity a function of the leasing model rather than of the licence. A company taking a small office and planning a team of research staff runs into floor area long before it runs into any immigration limit. The practical consequence: headcount belongs in the premises specification at the site-selection stage, not after the licence is issued — the more so because the number of employees in the zone carries independent weight for tax purposes, as set out below.

The Federal Layer: the Emirates Drug Establishment and Decree-Law No. 38 of 2024

The Emirates Drug Establishment is the federal authority responsible for regulating medical products across the UAE, free zones included. It was created by Federal Decree-Law No. 28 of 2023, which establishes “a federal institution called the Emirates Drug Establishment”, reporting to the Cabinet, with separate legal personality and financial and administrative independence. Its headquarters are in the Emirate of Abu Dhabi (article 4).

The scope of both federal instruments expressly reaches free zones. Article 2(1) of Decree-Law No. 28 of 2023 applies it to the listed medical products “in all areas of the State, including free zones”. Article 2(4) of Decree-Law No. 38 of 2024: “Pharmaceutical Establishments and Biobanks operating in the State, including those operating in free zones.”

Article 6 of Decree-Law No. 28 of 2023 states the body’s status: “The Corporation shall be the federal authority responsible for regulating medical products in the State.” Its powers then include: “Approve and register medical products and supervise them”; “Establish a pricing system for medical products in the State”; “Issue licenses for factories, compounding pharmacies, contract companies supporting the development and manufacture of medical products, medical product companies, pharmacies, pharmaceutical consulting offices, warehouses, stores, marketing offices, blood banks, and cord blood and stem cell storage centers”; “Issue marketing approvals for medical products and license marketing advertisements thereof”; and “Issue permits and approvals related to the import, export, re-export, manufacture, sale, distribution, display, possession, trade, storage, and disposal of medical products”.

When the Powers Actually Moved

The operational transfer of services from the Ministry of Health and Prevention to the Emirates Drug Establishment took place on 31 December 2025. According to the state news agency WAM on that date, the restructuring involves “the full transfer of 44 core services to the Emirates Drug Establishment, which will now be solely responsible for their administration, regulation, and oversight”. A further 13 services transferred partially — including, materially, “the licensing, renewal, reactivation, amendment, and cancellation of pharmaceutical facility licences”. The practical consequence: the licensing of pharmaceutical establishments did not move to the EDE in full, and the addressee should be confirmed procedure by procedure. Finally, 5 services remained wholly with the Ministry: issuing controlled-medicine prescription books, authorising narcotic drug custody for hospitals, setting and amending narcotic drug quotas, and approving narcotic drugs for in-house pharmacies in private hospitals and for day-surgery centres.

Legal succession is fixed by article 15 of Decree-Law No. 28 of 2023: the Establishment succeeds the Ministry of Health and Prevention and the Ministry of Climate Change and Environment “in all rights, obligations, and legal matters pertaining to the regulation and management of medical products”.

Subject of regulation	Regulator in 2026	Provision
Marketing approval for a medical product	EDE	arts. 5(1), 6(1) of Decree-Law No. 38 of 2024
Pricing of medical products	EDE	arts. 20, 105 of Decree-Law No. 38 of 2024
Import, export and re-export permits	EDE	arts. 31–32 of Decree-Law No. 38 of 2024
Advertising and promotion approval	EDE	arts. 44–47 of Decree-Law No. 38 of 2024
Medical warehouses and stores, marketing offices, pha­rmaceu­tical consulting offices, pha­rmaceu­tical laboratories, factories and contract manufacturers	EDE	arts. 98, 106, 113, 119, 126
Contract research and development companies	Ministry of Health and Prevention or the competent health authority	art. 134(1)
Bioe­quiva­lence centres	EDE or the competent health authority	art. 153(1)
Biobanks	EDE or the competent health authority	art. 140(1)
Clinical and non-clinical research entities	EDE or the competent health authority	art. 147(1)
General and compounding pharmacies	Ministry of Health and Prevention or the competent health authority	arts. 83(1), 92
Pharmacist licences inside EDE-licensed esta­blishme­nts	Ministry of Health and Prevention	art. 71(1)
Narcotic drugs: quotas, custody, prescription books	Ministry of Health and Prevention	WAM report of 31 December 2025

Article 71 draws the boundary more precisely than any other provision of the statute. Paragraph 1: “The Ministry shall be responsible for licensing the practice of the pharmacy profession in Pharmaceutical Establishments and Biobanks that are subject to the EDE license.” The EDE licenses the establishment; the Ministry licenses the pharmacist inside it. Paragraph 3 makes practising any pharmacy activity without that licence unlawful.

Article 174 assumes parallel rather than alternative licensing: the EDE, the Ministry and the competent health authority “shall establish a mechanism for mutual notification of licenses issued by them”.

Treat the English text of the federal instruments with care. The UAE legislation portal attaches a disclaimer that the Arabic prevails, and for Decree-Law No. 38 of 2024 that is not a formality. The English version of article 140(1) has biobanks licensed by “the Ministry”, where the Arabic says “المؤسسة” — the Emirates Drug Establishment; the Ministry’s own transfer notice confirms the Arabic by listing biobanks among the categories moved to the EDE. The English of article 2(1) introduces the qualifier “Hazardous Medical Products”, which the Arabic (“the following Medical Products”) does not contain. The practical consequence: an application filed on the English text of article 140(1) goes to the wrong regulator. The transfer of powers is examined in detail in our analysis of registering medicines and medical devices in the UAE.

What the EDE Registers: Marketing Approval, Price and Import

Without a marketing approval from the Emirates Drug Establishment, a medical product may not be imported, distributed, held, sold, displayed, used or manufactured. Article 5(1) of Decree-Law No. 38 of 2024: “it is not permitted to import, distribute, possess, sell, display, re-market, use, or manufacture any Medical Product in the State for circulation therein, except after obtaining Marketing Approval of any type from the EDE.”

Only four categories may apply. Article 6(1)(a): “The Applicant shall be a Pharmaceutical Establishment licensed as a Marketing Office, a Medical Products Manufacturer, a contracted Medical Products manufacturing company, or a Medical Warehouse designated by the Marketing Rights holder.” A company holding none of those four EDE licences cannot file a product registration at all.

A marketing approval runs for five years. Article 7(1): “The Marketing Approval shall be valid for a period of (5) five years, and shall be renewed for similar periods.” Renewal is applied for ninety days before expiry (article 7(2)).

The rights holder must appoint at least two importers. Article 22(1): “The Marketing Right Holder shall appoint at least two Pharmaceutical Establishments licensed by the EDE to import Medical Products into the State as importers of the Medical Product… and shall appoint one or more Pharmaceutical Establishments licensed in the State to distribute.”

The Price Is Set by the Regulator and Printed on the Pack

A product with marketing approval cannot circulate without a set price. Article 20: “The Marketing of a Medical Product that has obtained Marketing Approval requires the existence of a specific price for this product, which is determined in accordance with the general rules issued by a decision of the BOD.”

The public price goes on the outer packaging. Article 105(1) requires the medical warehouse to place the EDE-approved selling price on the pack “before selling and delivering it”; paragraph 2 makes the marketing rights holder, the responsible pharmacist and the owner jointly and severally liable for failure.

Departures from the price are prohibited in both directions, but the discount prohibition carries an express qualification. Article 101(5) forbids “Selling a priced Medical Product at a price higher than that set by the EDE”. Article 101(6) in full: “Granting discounts from the prices set by the EDE, and special prices may be set within the scope of implementing a system for dispensing Medical Products in accordance with what is specified in the Executive Regulations of this Decree-Law.”

The discount prohibition is regularly missed when a commercial model is designed — and its qualification more often still. A discount off the EDE price is as unlawful as an excess over it, yet the second half of the provision permits special prices to be set within a dispensing system “in accordance with what is specified in the Executive Regulations”. The practical consequence: tender and volume-discount mechanics on priced products need dedicated legal work — and since no Executive Regulation to Decree-Law No. 38 of 2024 has been issued, the content of that dispensing system is not set out in any instrument currently in force.

Import: a Permit for Every Shipment

Import, export and re-export of any medical product, raw material or pharmaceutical substance require EDE approval. Article 31(1): “It is not permitted to import, export or re-export any Medical Product or any raw materials or pharmaceutical raw materials used in its manufacture except after obtaining approval or permit from the EDE.”

The conditions are in article 32(1): a valid marketing approval or emergency use approval for the product concerned, and applicant status as a “Biobank, Pharmaceutical Laboratory, Non-Clinical and Clinical Research entity, Bioequivalence center, Medical Warehouse, Medical Products factory or contracted Medical Products manufacturing company licensed”. The EDE confirms compliance, shipping conditions included, by inspecting consignments (article 32(2)) and may restrict or prohibit import where public health is at risk (article 32(3)).

The permit is not transferable. Article 33(2): “The Ownership of the approval or import, export or re-export permit issued by the EDE may not be transferred to another party.”

The import fee is set by Cabinet Resolution No. 40 of 2025, issued 16 April 2025 and in force from 29 April 2025, Official Gazette No. 798. Article 3(3) in full: “A fee of (1%) of the total invoice value shall be collected for every import permit in respect of any medical products, raw materials, chemicals and precursors that are not subject to the prescribed tariff.”

A different rule applies to tariffed goods. Article 3(4) charges either 1% of the CIF value or 1% of the total invoice value, “whichever is higher”, and “In all cases, the fee amount shall not be less than AED (200) per invoice”. Article 3(6) exempts six categories, including free samples, samples for accredited research centres, tender samples, registration and analysis samples, goods for a passenger’s personal use, and replacements for damaged consignments.

A material point for a free zone company: the definition of import expressly captures movement from the zone onto the mainland. Article 1 defines Import as “Importing Medical Products in their final form or raw materials from outside the State or its free zones to the mainland or within the State through customs ports and after obtaining permit or approval from the EDE for each shipment.” The practical consequence: moving goods from a Dubai Science Park warehouse onto the Dubai mainland is an import for federal law purposes and needs an EDE permit for every consignment — even though the goods are already physically in the UAE.

Liability

Offence	Sanction	Provision
Circulating a product without marketing approval (art. 5(1)); importing without an EDE permit (art. 31(1))	imprisonment of 1 to 5 years and/or a fine of AED 100,000 to AED 500,000	art. 164(2)
Opening a pha­rmaceu­tical establishment or biobank without a licence; importing, distributing, marketing or promoting medical products without a licence	imprisonment of 6 months to 2 years and/or a fine of AED 50,000 to AED 200,000	art. 164(1)
Operating after the licence has expired; dealing with unlicensed esta­blishme­nts; advertising without approval (art. 44)	imprisonment of 6 months to 1 year and/or a fine of AED 50,000 to AED 200,000	art. 165(1)
Breaching the EDE-approved price	fine of up to AED 100,000, doubled on repetition	art. 166 (Arabic text)
Cou­nterfei­ting a product; selling or smuggling a counterfeit	temporary imprisonment and a fine of AED 200,000 to AED 1,000,000	art. 167 (Arabic text)
Disciplinary sanctions against esta­bli­shments	written notice; written warning; fine of AED 1,000 to AED 1,000,000; licence suspension up to 6 months; licence cancellation	art. 160(1)(a) (Arabic text)

The English text of articles 160, 166 and 167 carries evident translation defects — “on hundred thousand AED (1,000)”, “two one hundred thousand AED (100,000)”, “not exceeding two million AED (1,000,000)”. The figures above are taken from the Arabic, which prevails under the portal’s own disclaimer. The practical consequence: sanction amounts cannot be quoted from the English version.

Medical Devices: Classes, Timelines and Fees

Medical devices in the UAE are registered by the Emirates Drug Establishment, and registration is mandatory before import and before sale. A medical device falls within “Medical Equipment”, which article 2(1)(b) of Decree-Law No. 38 of 2024 classifies as a medical product, bringing it squarely within the article 5(1) prohibition.

The article 1 definition of “Medical Equipment” reads: “A Medical Product that contains a substance, device, instrument, engine, implant, detector, or system, including accessories, and operating software thereof. It shall include wearable devices and products based on AI technology, which shall achieve the intended purpose of its use in or on the human or animal body without a pharmaceutical, immune, or metabolic effect. In addition, it is manufactured, sold, or offered for use in the following cases: 1. Diagnosis, treatment, cure, relief, or prevention of a disease, an injury, or a disability; 2. Detection, modification, or replacement of anatomical position. 3. Birth Control.”

Note that the definition expressly captures wearable devices and AI-based products. That matters for a medtech company building software or wearable diagnostics: whether it falls inside turns on the claimed intended purpose, not on the physical form of the product.

The Emirates Drug Establishment publishes the parameters of its device registration service.

Parameter of the “Issuance of Marketing Authorization for a Medical Device” service	Value
Service completion duration	45 working days
Application fee	AED 100
Re­gistra­tion fee for a medical device	AED 5,000
Cla­ssifi­cation	Class I, II, III, IV
Conformity evidence accepted	EC, 510(k), PMA — according to class
Target audience of the service	medical warehouses, local pha­rmaceu­tical manu­factu­rers, marketing offices
Validity of the marketing approval	5 years (art. 7(1) of Decree-Law No. 38 of 2024)

Two preconditions are stated in the service description in terms: “Marketing Authorization Holder companies must be registered by Emirates Drug Establishment before they could register their products” and “The marketing office or medical warehouse must be licensed by the Emirates Drug Establishment and have a valid license.”

The sequence does not permit reordering: the establishment licence first, then product registration, then a shipment import permit. A company that begins by trying to register a device finds there is no one to accept the filing — only an EDE-licensed marketing office or medical warehouse can be the applicant.

A device-only warehouse enjoys a staffing concession. Article 98(2)(c): “if the activity of the Medical Warehouse or Medical Store is limited to medical equipment, it may be managed by a medical equipment engineer or a specialist in one of the health professions who is licensed and dedicated to working in it.” No responsible pharmacist is required for a pure medtech warehouse — and with that, the article 71(1) Ministry pharmacist licence falls away too.

Warehouses and marketing offices in free zones are exempt from the national shareholding requirement. Article 98(4) for warehouses and stores, article 106(4) for marketing offices. This is one of the few places where being in a free zone yields a direct concession under the federal pharmaceutical law.

The author’s assessment: what the published sources do not contain is the classification rules themselves.The Emirates Drug Establishment publishes that there are four classes and that CE, 510(k) and PMA evidence is accepted, but no published instrument setting out the criteria for assigning a device to a class could be located; a separate “Classification of a Medical Product” service exists and is described procedurally only. The practical consequence: it is not possible, on publicly available material, to state which classification system the UAE applies — IMDRF rules, the European regulation or a domestic methodology — and a device’s class should be confirmed by asking the EDE rather than inferred from its European or US registration.

The Emirate Layer: the DHA Licenses Facilities and Professionals, Free Zones Included

The Dubai Health Authority licenses healthcare facilities and healthcare professionals across the whole emirate, expressly including free zones and special development zones. Both the constituting law and the operative subordinate instrument say so.

Dubai Law No. 6 of 2018, article 6, reads: “3. authorise individuals and Government and private facilities, including individuals and facilities operating in Special Development Zones and free zones such as the Dubai International Financial Centre, to practise the Profession in the Emirate…; 4. audit and inspect Healthcare Facilities, including those operating in Special Development Zones and free zones…; 7. regulate and approve, in coordination with concerned entities, prices for the Health Services provided by private Healthcare Facilities in the Emirate; 15. manage, regulate, and authorise the content of health-related advertisements in the Emirate.”

Note what article 6 does not contain: any power to register medical products, price medicines, or license pharmaceutical establishments in the sense of Decree-Law No. 38 of 2024. The DHA’s remit is facilities, professionals, health insurance, the content of health advertising, and the price of health services. It has no product layer at all.

The operative subordinate instrument is Executive Council Resolution No. 49 of 2024, issued on 28 August 2024, in force sixty days after publication, superseding Resolution No. 32 of 2012.

Scope, article 2(a): “the provisions of this Resolution apply to: 1. all facilities engaged in practising Health Activities across the Emirate, including in Special Development Zones and free zones…; 2. any person practising the Health Profession within Government Healthcare Facilities, Private Healthcare Facilities, or any other Healthcare Facilities.” There are two exclusions. Paragraph (c) takes federal government entities and their healthcare facilities outside the Resolution. Paragraph (b) narrows the sanctions: the provisions “prescribing penalties and punitive measures do not apply to the Government Entities engaged in practising Health Activities in the Emirate pursuant to their establishing or governing legislation”.

The two-key rule is in article 7(a): “No natural or legal person may establish a facility to conduct Health Activities within the Emirate unless that facility is licensed by the Concerned Entities and has obtained a Licence from the DHA.” Paragraph (b) requires a licence for every individual practising a health profession; paragraph (c) forbids a facility to engage a professional not authorised by the DHA to work there.

For a Dubai Science Park tenant, the “Concerned Entities” in article 7(a) means the Dubai Development Authority. The practical consequence: both the DDA licence and the DHA licence are required, and in that order — the DDA confers the right to exist and trade in the zone, the DHA the right to deliver health services.

The detailed requirements are approved by Administrative Resolution No. 25 of 2025 of the DHA’s Director General, issued 12 March 2025, which approves “the Manual for Licensing Healthcare Facilities; the Manual for Licensing Healthcare Professionals; and the Protocol for Practising Healthcare Activities and Professions” and, by article 3, makes compliance mandatory. Version 1.1 of the facility licensing manual, dated 20 November 2024, includes “Medical Laboratory”, “Radio-Diagnostic Center” and “Diagnostic Center (Multiple Specialties)” among the licensable types. The full procedure is examined in our analysis of licensing a healthcare facility in Dubai through the DHA.

Dubai Law No. 5 of 2025 on public health reaches every zone in the emirate. Article 4: “The provisions of this Law apply in all zones across the Emirate, including in Special Development Zones and free zones.” It comes into force ninety days after publication.

Dubai Healthcare City: Why It Is Beside the Point

Dubai Healthcare City is a geographically bounded free zone, and its regime does not reach a company in Dubai Science Park. Dubai Law No. 16 of 2024, issued 4 September 2024 and superseding Law No. 9 of 2011, applies to DHCC “whose boundaries and area are demarcated on the map attached herewith”. Dubai Science Park is licensed by the DDA and lies outside that map.

The Dubai Healthcare City Authority (DHCA) does retain licensing and inspection powers inside its own zone, but exercises them subject to the DHA’s priority. Article 5(a) of Law No. 16 of 2024 empowers it to “determine and regulate the business and activities authorised within the DHCC, and set the rules, conditions, requirements, and procedures for licensing such business and activities”, to “register and license companies, establishments, and other entities within the DHCC” and to “audit and inspect DHCC Establishments and their activities”. Article 5(b) makes those functions “subject to the powers and functions vested in the DHA and other competent entities”, and article 6 preserves for the DHA, among other things, “the powers of the DHA to record the acts committed in breach of the legislation regulating the Health Sector, and to impose the fines and administrative penalties”. Executive Council Resolution No. 49 of 2024 contains no DHCC carve-out at all, and article 8.2 of DDA Decision No. 1 of 2021 still names “DHA or DHCA” as the approving body.

The author’s assessment: since 2024, choosing Dubai Healthcare City over Dubai Science Park buys a different zone regulator, not a different health supervision regime. The saving in article 7 of Law No. 6 of 2018 is drawn more widely than a reference to Law No. 9 of 2011 — it preserves the DHCC authority’s powers “pursuant to the above-mentioned Law No. (9) of 2011 and other legislation in force in the Emirate” — and so carries over to Law No. 16 of 2024. What changed is not the existence of those powers but their subordination: article 5(b) makes them expressly “subject to the powers and functions vested in the DHA”. The practical consequence: health supervision in both zones is the DHA’s, and Dubai Science Park and Dubai Healthcare City should be compared on infrastructure, adjacency and cost rather than on the extent of health regulation.

Four Business Models: Where the DDA Licence Suffices, and Where It Does Not

In none of the four business models typical of Dubai Science Park is the DDA licence sufficient. It is necessary — it is what satisfies the “licensed by the Concerned Entities” limb of article 7(a) of Resolution No. 49 of 2024 — but in no case is it the only licence needed.

Business model	DDA licence	EDE licence	DHA licence	Ministry of Health licence
Re­prese­ntative office promoting a manu­factu­rer’s registered medicine	segment 23.1, activity 23.1.3 Marketing and Sales Promotion	Marketing Office — art. 106(1); plus product marketing approval and separate advertising approval	not required	pharmacist licence only if a pharmacist is employed (art. 71(1))
Importer and distributor of medicines	segment 23.1, activities Storage and Import and Re-Export	Medical Warehouse — art. 98(1), plus a separate import licence under art. 98(2)(d), plus a permit for every consignment under art. 31	not required	responsible pharmacist licence — mandatory
Medical device distributor	segment 23.5	Medical Warehouse or Medical Store; marketing approval for each device; consignment permit	not required for distribution	not requiredwhere the activity is device-only — art. 98(2)(c)
Diagnostics laboratory testing patient samples	segment 23.7 Diagnostics and Analysis	only in three situations — see below	mandatory — art. 7(a) of Resolution No. 49 of 2024; plus licences for every professional	not required

What Matters in Each Model

The representative office: there is no “scientific office” in the statute, although the district’s operator uses the term.The phrase “scientific office” appears nowhere in the English text of Decree-Law No. 38 of 2024, and “مكتب علمي” nowhere in the Arabic. Yet the Dubai Science Park FAQ answers: “Can I setup a scientific office in DSP? Yes. Dubai Science Park has signed an MOU with the Ministry of Health which allows our registered business partners to apply for scientific office approval for their leased premises in DSP”, linking to the Ministry of Health’s pharmaceutical facility licensing page.

The divergence resolves in favour of the instrument, but it is informative in itself. The operator’s wording describes an administrative practice — a memorandum with the Ministry and an application under its procedure — that took shape before the 2024–2025 reform. The operative statutory vehicle is the Marketing Office, licensed by the Emirates Drug Establishment, and the licensing of pharmaceutical establishments moved to the EDE only in part. The practical consequence: when a “scientific office” is discussed with the operator, translate the conversation into article 106 terms at once and establish which regulator the 2026 application actually goes to.

The statutory vehicle is the Marketing Office, defined in article 1 as “A Pharmaceutical Establishment licensed to practice the activity of introducing Medical Products to healthcare professionals and monitoring their circulation in the State.” The licence conditions in article 106(2) include documentary proof that the applicant “represents the Owner of the Marketing Rights for the Medical Product to be marketed in the State”.

The marketing office’s prohibitions are listed in article 109, and the list is open-ended: “1. Practice any activity not licensed. 2. Importing or storing Medical Products for sale or distribution. 3. Dealing with other unlicensed Pharmaceutical Establishments. 4. Any other prohibitions specified by the Executive Regulations of this Decree-Law.” With no Executive Regulation to Decree-Law No. 38 of 2024 issued, the fourth limb is as yet unfilled. The marketing office may import only through a licensed medical warehouse it has appointed, and with EDE approval (article 110(1)); free samples are permitted, stamped “Free Medical Sample Not for Sale” in Arabic and English.

Advertising and promotion require separate approval for each product. Article 44(1): “It is prohibited to advertise, publicize or promote Medical Products by any means… unless approved by the EDE.” Article 46: approval runs “from (30) thirty days to one year… The Applicant shall obtain a new approval for each Medical Product he wishes to advertise.”

The Emirates Drug Establishment’s published parameters for the two key licences:

Parameter	Marketing Office	Medical Warehouse
Service completion duration	3 working days	3 working days for each step
Application fee	AED 100	AED 100
Initial inspection	AED 1,000 per inspection	AED 1,000 per inspection
Final inspection	AED 1,000 per inspection	AED 1,000 per inspection
Final licence fee	AED 10,000	AED 7,500; for a warehouse with export rights, AED 10,000

The medicines importer: a good storage and distribution certificate is mandatory. Article 98(2) requires “a valid Good Storage and Distribution Practice Certificate from the EDE” and technical management by a licensed pharmacist dedicated to working at the warehouse.

The diagnostics laboratory: the DHA is the primary regulator, but the EDE appears in three situations. First, where the laboratory stores biological samples for future use, it is a biobank under article 1 and is licensed under article 140(1). Second, where it tests medical products — stability, quality, batch release — rather than patient samples, it is a Pharmaceutical Laboratory under article 119(1) and is licensed by the EDE. Third, where it imports reagents and in vitro diagnostics, articles 5(1) and 31(1) apply in full.

Note a distinction easily missed at the segment-selection stage: “Diagnostics and Analysis” under segment 23.7 requires no prior health-regulator approval at the level of the DDA Decision, whereas “Medical Laboratory” as General Segment activity 26.2.8 does. Article 8.2 of Decision No. 1 of 2021 lists the activities whose licensing and renewal are conditioned on approvals or no-objection certificates, and Medical Laboratory appears there marked “DHA or DHCA”. The practical consequence: commercially similar wording leads to different procedures, and the choice of segment determines whether DHA approval is needed before the DDA licence issues or after it.

The author’s assessment: the only situation in which a Dubai Science Park company needs nothing beyond the DDA licence is one touching neither medical products nor patients. Back office, holding, software that is not a medical device, scientific consultancy falling outside the “Pharmaceutical Consulting Office” of article 113. The practical consequence: plan on the presumption that a second and a third licence will be required, not on the presumption that the zone licence is enough.

VAT: Why Dubai Science Park Is Not a Designated Zone, and What That Changes

Dubai Science Park is not on the list of Designated Zones for VAT purposes. The consolidated list published by the Federal Tax Authority rests on Cabinet Decision No. 59 of 2017 as amended by Cabinet Decisions No. 35 of 2018, No. 43 of 2019, No. 34 of 2021, No. 63 of 2021 and No. 81 of 2021, the last of which took effect on 12 September 2021.

Dubai zone on the list	In force from	Ceased
Jebel Ali Free Zone (North-South)	01/01/2018	—
Dubai Cars and Automotive Zone (DUCAMZ)	01/01/2018	—
Dubai Textile City	01/01/2018	04/04/2021
Free Zone Area in Al Quoz	01/01/2018	01/07/2021
DAFZA Industrial Park Free Zone — Al Qusais	01/01/2018	—
Dubai Aviation City	01/01/2018	—
Dubai Airport Free Zone	01/01/2018	—
International Humanitarian City Jebel Ali	18/06/2018	—
Dubai CommerCity	01/01/2021	—
Dubai Science Park	not on the list	—

Of the nine Dubai entries, seven remain live. No zone administered by the Dubai Development Authority appears on the list at all.

Article 50 of the VAT Law states the consequence of the status briefly: “A ‘Designated Zone’ that meets the conditions specified in the Executive Regulation of this Decree-Law shall be treated as being outside the State.” The conditions sit in article 51(1) of the Executive Regulation: a fenced area with security measures and customs controls, internal procedures for keeping, storing and processing goods, and compliance by the operator with the Authority’s procedures.

What a Company Without Designated Zone Status Actually Loses — and Does Not

The Designated Zone benefit runs to goods only and never ran to services. Article 51(6) of the Executive Regulation: “The place of supply of any Services is considered to be inside the State if the place of supply is in the Designated Zone.” Research services, testing and regulatory support supplied from Dubai Science Park would be taxed identically inside a Designated Zone.

Designated Zone status was never a shelter from registration. Article 51(10): “Any Person established, registered or which has a Place of Residence in a Designated Zone shall be deemed to have a Place of Residence in the State for the purposes of the Decree-Law.”

What a Dubai Science Park company genuinely cannot access is tax-free movement of goods between Designated Zones. Article 51 of the VAT Law and article 51(3) of the Executive Regulation permit that movement provided the goods are not released, used or altered and the transfer proceeds under customs suspension. Bringing goods from the Jebel Ali Free Zone into Dubai Science Park is not such a movement.

Zero-Rating for Medicines and Devices Does Not Depend on the Zone

The supply and import of registered medicines and medical equipment are zero-rated regardless of whether the supplier sits in a free zone. The chain runs: article 45(14) of the VAT Law → article 41(4) of the Executive Regulation → Cabinet Decision No. 56 of 2017.

Article 2 of Cabinet Decision No. 56 of 2017 reads: “The supply of Medications and Medical Equipment registered with the Ministry of Health and Prevention, or imported with its permission or approval, shall be subject to tax at zero rate.” The Decision was issued on 28 December 2017 and applies from 1 January 2018.

The qualifying mechanism is registrational, not territorial. The provision contains no Designated Zone condition, no free zone condition and no condition about who supplies the goods. A Dubai Science Park company zero-rates registered medicines and devices on exactly the same footing as a mainland company, and the absence of Designated Zone status costs it nothing here.

Note a mismatch that has opened up since 31 December 2025. Cabinet Decision No. 56 of 2017 keys zero-rating to registration “with the Ministry of Health and Prevention”, whereas since 31 December 2025 medical products have been registered by the Emirates Drug Establishment, to which the powers passed by succession under article 15 of Decree-Law No. 28 of 2023. No textual update to Cabinet Decision No. 56 of 2017 could be located. Zero-rating continues to apply in practice by force of that succession, but the provision as drafted points at a body that no longer performs the function. The practical consequence: build the 2026 evidence file for zero-rating on the EDE approval, accompanied by the succession point, rather than on a Ministry registration that no longer exists.

Healthcare services are zero-rated on a separate footing. Article 41(2) of the Executive Regulation conditions zero-rating on the supply being made “by a healthcare body or institution, doctor, nurse, technician, dentist, or pharmacy, licensed by the Ministry of Health and Prevention or by any other competent authority concerned with healthcare” and on its relating to the wellbeing of a human being. For a laboratory in Dubai Science Park, that competent authority is the Dubai Health Authority. The wider VAT mechanics are covered in our complete UAE VAT guide, and how a zone with Designated Zone status actually works is examined through Jebel Ali Free Zone.

Corporate Tax: Which Qualifying Activities Are Available

The 0% rate applies to the qualifying income of a Qualifying Free Zone Person, and a Dubai Science Park company can reach five of the fourteen qualifying activities — but not the distribution of goods. The list is in article 2(1) of Ministerial Decision No. 229 of 2025, issued 28 August 2025; article 6 repealed Ministerial Decision No. 265 of 2023, and article 7 applies the new decision from 1 June 2023.

The fourteen qualifying activities read: “a. Manufacturing of goods or materials. b. Processing of goods or materials. c. Trading of Qualifying Commodities. d. Holding of shares and other securities for investment purposes. e. Ownership, management and operation of Ships. f. Reinsurance services. g. Fund management services. h. Wealth and investment management services. i. Headquarter services to Related Parties. j. Treasury and financing services to Related Parties or for its own account. k. Financing and leasing of Aircrafts. l. Distribution of goods or materials in or from a Designated Zone. m. Logistics services. n. Any activities that are ancillary to the Qualifying Activities specified in paragraphs (a) to (m).”

Activity	Available to a Dubai Science Park company	Why
Ma­nufactu­ring of goods or materials (a)	yes	No Designated Zone condition. Defined as “the production, improvement or assembly of products and materials from raw materials or components”
Processing of goods or materials (b)	yes	No Designated Zone condition. Defined as “the preparation, treatment, tra­nsforma­tion or conversion of goods or materials into another form of good or material”
Holding of shares and other securities (d)	yes	No Designated Zone condition; requires uninterrupted holding of at least 12 months
Headquarter services to Related Parties (i)	yes	No Designated Zone condition; recipients must be Related Parties
Logistics services (m)	yes, but narrowly	No Designated Zone condition, but the definition requires storage and tra­nsporta­tion “without taking title to the good or material of that other Person”
Di­stri­bution of goods (l)	no	Requires the activity to be “in or from a Designated Zone”, imported goods to enter the State “through the Designated Zone”, and the customer to be one who resells, processes or alters the goods for the purposes of sale or resale, or a public benefit entity. Dubai Science Park is not a Designated Zone
Research and development	not a qualifying activity	It does not appear anywhere among the fourteen

The decisive distinction for a pharma or medtech business is the passing of title. A Dubai Science Park company that stores and moves someone else’s goods falls within logistics services. A company that buys goods into its own ownership and resells them is distributing — and distribution is closed to it. The practical consequence: a “buy, import, sell onshore” model run from Dubai Science Park produces no qualifying income, whereas a “manufacture or process, then sell” model produces it with no zone condition at all.

Since 2026 the Designated Zone distribution route has become heavier still. Federal Tax Authority Decision No. 6 of 2026, issued 2 June 2026 and applying to tax periods beginning on or after 1 January 2026, requires a Qualifying Free Zone Person relying on paragraph (l) to obtain from an independent external auditor an agreed-upon procedures report under ISRS 4400 and to file it “no later than thirty (30) days following the deadline to file the Corporate Tax return”. Absent that report, the paragraph (l) conditions “shall not be considered to be met”. The practical consequence: the gap between a Designated Zone distributor and a Dubai Science Park manufacturer widened in 2026 — the latter needs no such report at all.

Excluded Activities: Where the Life-Sciences Trap Lies

Excluded activities are listed in article 2(2) of Ministerial Decision No. 229 of 2025, and the first item is the dangerous one. It reads: “a. Any transactions with natural persons, except transactions in relation to the Qualifying Activities specified under paragraphs (e), (g), (h) and (k) of Clause (1) of this Article.”

The carve-outs are ships, fund management, wealth management and aircraft financing. Not one life-sciences activity is carved out.

The practical consequence: any sales to individuals are an excluded activity. Direct-to-patient sales, consumer genetic tests, home diagnostic kits, a telemedicine pharmacy — all of that revenue is non-qualifying however the rest of the structure is built. A sale to a doctor practising as an individual rather than through a company falls into the same trap.

The second relevant item is real estate. Paragraph (e) excludes the ownership or exploitation of immovable property, other than commercial property located in a free zone where the transaction is with a Free Zone Person. Letting laboratory space in Dubai Science Park to a mainland tenant is an excluded activity.

The De Minimis Threshold and What It Costs

The de minimis requirement is met where non-qualifying revenue does not exceed 5% of total revenue or AED 5,000,000, whichever is lower. Article 3 of Ministerial Decision No. 229 of 2025. The test runs on revenue, not profit.

Non-qualifying revenue is defined by article 4(2)(a) of Cabinet Decision No. 100 of 2023: revenue from excluded activities; revenue from activities that are not qualifying activities where the counterparty is not a Free Zone Person; and revenue from transactions with a Free Zone Person that is not the Beneficial Recipient.

Breach costs the status for five years, and the rule sits in the Ministerial Decision rather than the Cabinet Decision.Article 5(2) of Ministerial Decision No. 229 of 2025: a person that ceases to meet the conditions “at any particular time during a Tax Period” loses the status “from the beginning of the relevant Tax Period and for the subsequent (4) four Tax Periods”. Article 5 of Cabinet Decision No. 100 of 2023 addresses a different subject — income attributable to a permanent establishment.

Note the structural exit the legislation itself provides. Article 4(3)(b) of Cabinet Decision No. 100 of 2023 excludes revenue attributable to a domestic permanent establishment from both the numerator and the denominator. The practical consequence: mainland sales routed through a properly constituted branch are taxed at 9% but do not break the de minimis threshold — unlike the same sales made directly from the zone. The conditions of Qualifying Free Zone Person status are examined in detail in our dedicated analysis.

The substance requirement should not be underestimated. Article 8 of Cabinet Decision No. 100 of 2023 requires the core income-generating activities to be carried on in a free zone — in a Designated Zone for distribution — with adequate assets there, an adequate number of qualified full-time employees, and adequate operating expenditure. For a Dubai Science Park company, this ties the tax position directly to leased floor area, through the one-visa-per-80-square-feet rule.

R&D: Not a Qualifying Activity — and a Tax Credit the 0% Rate Cancels Out

Research and development is not among the qualifying activities, and that is the central tax problem for a biotech company in a free zone. Article 2(1) of Ministerial Decision No. 229 of 2025 lists fourteen items from (a) to (n), and not one of them is research, laboratory services, clinical trials or contract research.

The consequences are fixed by the provisions themselves.

•          Research services supplied to a person outside the free zones — a mainland hospital, a foreign sponsor, a mainland contract research organisation — are not qualifying income under article 3(1)(b) of Cabinet Decision No. 100 of 2023 and land in the numerator of the de minimis test.

•          Research services supplied to a Free Zone Person that is the Beneficial Recipient are qualifying income, under article 3(1)(a), which imposes no qualifying activity condition at all. That is the only clean route for R&D income.

•          In-house research serving the company’s own manufacturing may be caught as an ancillary activity under paragraph (n). Article 2(4) defines ancillary as “necessary for the performance of the main activity or where it makes a minor contribution to it and is so closely related to the main activity that it should not be regarded as a separate activity”. That works for internal R&D alongside the company’s own manufacturing; it does not work for R&D sold as a service.

The Qualifying Intellectual Property Route

Qualifying intellectual property is an independent head of qualifying income, not an activity. The definition in article 1 of Cabinet Decision No. 100 of 2023 reads: “Patents, Copyrighted Software and any right functionally equivalent to a Patent that is both legally protected and subject to a similar approval and registration process to a Patent, such as utility models, intellectual property assets that grant protection to plants and genetic material, orphan drug designations, and extensions of Patent protection, but not including any marketing related intellectual property assets, such as trademarks.”

The express reference to orphan drug designations and to protection for genetic material is a provision written for life sciences. The practical consequence: a biotech reaches the relief not through its research activity as such but through the output of that research, formalised as a patent, as software or as an orphan designation. Trademarks are expressly excluded.

The nexus machinery sits in article 4 of Ministerial Decision No. 229 of 2025. Qualifying expenditures are “expenditures incurred to fund research and development activities, conducted either by the Qualifying Free Zone Person or outsourced to any Person in the State or any Person outside the State that is not a Related Party, directly connected with the creation, invention or significant development of the Qualifying Intellectual Property”. The uplift is 30% of qualifying expenditure and applies only so far as qualifying expenditure, after uplift, does not exceed overall expenditure (article 4(3)).

The outsourcing rule for intellectual property is softer than the general one. Article 8(3) of Cabinet Decision No. 100 of 2023 permits the core income-generating activities in respect of qualifying intellectual property to be outsourced “to any other Person in the State and to any other Person who is not a Related Party outside the State”, subject to adequate supervision. A Dubai Science Park company can therefore use mainland contract research organisations and unrelated foreign laboratories without losing the relief.

The R&D Tax Credit, and Why It Is Incompatible with the 0% Rate

Cabinet Decision No. 215 of 2025 introduced an R&D tax credit applying to tax periods beginning on or after 1 January 2026. The Decision was issued on 31 December 2025; the rates were set by Ministerial Decision No. 24 of 2026, issued on 18 March 2026 and effective on issuance.

Band of qualifying R&D expenditure in the period	Minimum average number of R&D staff	Credit rate
the first AED 1,000,000	at least 2	15%
above AED 1,000,000 up to AED 2,000,000	at least 6	35%
above AED 2,000,000 up to AED 5,000,000	at least 14	50%

The rates apply band by band, not to the total. Both conditions at each tier are cumulative: article 2(7) of Ministerial Decision No. 24 of 2026 adjusts the rate down to the highest tier at which both thresholds are satisfied. The maximum credit, on full use of the AED 5,000,000 expenditure ceiling, is AED 2,000,000.

The minimum project size is AED 500,000. Article 5(3)(b) of Cabinet Decision No. 215 of 2025 requires expenditure of “at least AED 500,000 for each R&D Project in the relevant Tax Period or Fiscal Year excluding any uplift to staff costs”. Staff costs are uplifted by 30% to account for overheads (article 8(3) of Ministerial Decision No. 24 of 2026).

Pre-approval from the Emirates Research and Development Council is mandatory. Article 3(1)(b) of Cabinet Decision No. 215 of 2025 and article 4(1) of Ministerial Decision No. 24 of 2026; the form, manner and timeline are set by the Council itself. The claim is filed as part of the tax return, and a late claim “shall not be considered unless otherwise accepted by the Authority in exceptional circumstances” (article 9(3)).

The credit is non-refundable, but that is the Minister’s decision rather than the Cabinet Decision’s. Article 2(2) of Cabinet Decision No. 215 of 2025 leaves it open: the credit is set against liability “and may be refunded in accordance with a decision issued by the Minister”, and article 2(3)(b) tasks the Minister with determining “Whether the R&D Tax Credit is refundable or non-refundable”. Article 2(2) of Ministerial Decision No. 24 of 2026 made that determination: the credit “shall be non-refundable”. The practical consequence: non-refundability rests on a second-tier instrument and can be revisited without amending the Cabinet Decision. Any unused balance carries forward.

And here is the crux: article 3(2) of Cabinet Decision No. 215 of 2025 puts a Qualifying Free Zone Person in a special position. It reads: “where the Qualifying Entity is a Qualifying Free Zone Person, it must meet any of the following conditions: a. It is subject to Corporate Tax at a rate of 9% on Taxable Income for the Tax Period in which the Qualifying R&D Expenditure is incurred, and such Taxable Income is derived from the Qualifying R&D Activities. b. It is subject to the Top-up Tax for the Fiscal Year in which the Qualifying R&D Expenditure is incurred.” A company whose relevant income is all taxed at 0% and which is outside the Top-up Tax satisfies neither limb and cannot claim.

Becoming a Qualifying Free Zone Person triggers a claw-back of credit already used. Article 16(2) of Ministerial Decision No. 24 of 2026: where within five years of the end of the period in which a credit was last claimed the entity ceases to be a taxable person, becomes a Qualifying Free Zone Person, applies small business relief, enters liquidation or redomiciles out of the State, the credit used “shall be clawed back to the Authority as Payable Tax or Due Tax”, and any unused credit is forfeited. There is an exception: article 16(3) disapplies paragraph 2 “to a business restructuring transaction that is carried out in accordance with Article (7) of this Decision”.

The author’s assessment: for a biotech, the 0% rate and the R&D tax credit are mutually exclusive regimes, and the choice belongs at the structuring stage rather than after the first profitable year. A company whose economics rest on years of research before revenue gains nothing from a 0% rate — there is nothing to tax — yet that is precisely the population the credit is aimed at. A company with profitable manufacturing in the zone gains from the 0% rate and cannot claim the credit. The practical consequence: splitting the research function from the manufacturing and commercial function across two entities with different tax statuses is not optimisation but a direct consequence of article 3(2), and it needs to be thought through before the first application to the Council. The credit itself is examined separately in our analysis of the UAE R&D tax credit.

Operating on the Dubai Mainland: Executive Council Resolution No. 11 of 2025

A free zone company may carry on activities outside the zone within Dubai, on a licence or permit from the Department of Economy and Tourism and with the consent of its zone regulator. The mechanism is set by Executive Council Resolution No. 11 of 2025, issued 3 March 2025. Article 15: the Resolution “will be published in the Official Gazette and will come into force on the day on which it is published” — so commencement runs from publication rather than issue, and the publication date could not be established from the available sources.

Scope, article 2: “The provisions of this Resolution apply to the Establishments wishing to conduct their Activities outside of Free Zones. This Resolution does not apply to financial Establishments licensed to operate in the Dubai International Financial Centre.”

Instrument under article 4	Validity	Fee under article 12
Licence for a branch of the establishment within the emirate	1 year, renewable	no fee set by article 12; article 5(a)(6) refers to “applicable legislation”
Licence for a branch operating out of the free zone	1 year, renewable	AED 10,000 per year
Permit to conduct specific activities within the emirate	—	—
Temporary permit under article 7	not more than 6 months	AED 5,000

Two conditions matter in practice. First, the zone regulator’s consent is required under both routes, but the wording differs. Article 5(a)(2): “The prior approval of the Licensing Authority must be obtained.” Articles 6(a)(3) and 7(3): “The approval of the Licensing Authority must be obtained,” without “prior”. For Dubai Science Park that authority is the Dubai Development Authority. Second, article 3(b)(2) requires the company to “maintain separate financial records for the Activities conducted outside of the Free Zone and within the Emirate, distinct from those kept for Activities conducted within the Free Zone”.

The branch has no separate legal personality. Articles 5(b) and 6(b): a branch “will have no separate legal personality nor be deemed independent of its parent Company”.

Staff stay with the zone. Article 8: the establishment “may engage its existing workforce registered on the Free Zone portal, and may continue to benefit from all Free Zone employment privileges applicable to that workforce”.

Companies already operating onshore at the effective date were given a year to comply. Article 13, extendable once by the Director General.

Note that Resolution No. 11 of 2025 contains no tax provision at all. It is a licensing instrument of the Emirate of Dubai, and it amends neither the Corporate Tax Law, nor Cabinet Decision No. 100 of 2023, nor Ministerial Decision No. 229 of 2025, nor the VAT legislation — and as an emirate-level instrument it could not. The separate-records requirement in article 3(b)(2) is a licensing obligation owed to the Department of Economy and Tourism, not a tax provision.

The tax consequences flow, unchanged, from the pre-existing federal instruments. A mainland branch is a presence outside the free zone, that is, a domestic permanent establishment: Cabinet Decision No. 100 of 2023 defines one as “a place of Business or other form of presence of a Qualifying Free Zone Person outside the Free Zone in the State”. Article 5(1): income attributable to such an establishment “shall be considered Taxable Income” and is taxed at the general rate. Article 5(2) requires it to be computed “as if the establishment was a separate and independent Person that is a Related Party of the Qualifying Free Zone Person”.

The Federal Tax Authority’s guidance says the same. “Free Zone Persons — Corporate Tax Guide | CTGFZP1”, May 2024, section 3.2.1: “In either scenario, the 0% Corporate Tax rate on Qualifying Income applies only to its Free Zone Business, (i.e. the portion of the Business that is registered in the Free Zone)… the head office (Domestic Permanent Establishment or Foreign Permanent Establishment) would not be eligible for the 0% Corporate Tax rate, but the branch in the Free Zone would.”

The author’s assessment: Resolution No. 11 of 2025 makes onshore operation lawful without making it tax-free — and that is precisely where its value lies for a Dubai Science Park company. Because distribution as a qualifying activity is closed to the district, direct sales to mainland customers from the zone generate non-qualifying revenue and consume the de minimis threshold. Sales through a branch are taxed at 9% but are excluded from that threshold by article 4(3)(b) of Cabinet Decision No. 100 of 2023. The practical consequence: for a pharmaceutical or medtech distributor in Dubai Science Park, a mainland branch is not an extra burden but a way of protecting the 0% rate on everything else. The separate-records duty in article 3(b)(2) and the separate-computation duty in article 5(2) point the same way while remaining legally distinct obligations. The comparison between mainland and free zone regimes is examined separately inMainland vs Free Zone.

Note separately an official text that has fallen out of date: as at the date of publication, the Dubai Science Park FAQ still answers the question about operating outside the zone with “No, you can only operate within the free zone.” That wording predates Resolution No. 11 of 2025 and does not reflect the current position. The practical consequence: the operator’s materials cannot be relied on here — the Executive Council instrument governs.

A Step-by-Step Algorithm

Step 1. Establish whether the product falls within “medical product” under article 2 of Decree-Law No. 38 of 2024.The list covers pharmaceutical products, medical devices, healthcare products, biological products, food supplements, cosmetics and genetically modified organism products for medical use. Wearable devices and AI-based products are expressly within the definition of a medical device.

Step 2. Choose the segment and activity from Part Eight of DDA Decision No. 1 of 2021 — before filing.Therapeutics (23.1) for pharmaceuticals, Medical/Scientific Devices or Equipment (23.5) for medtech, Diagnostics and Analysis (23.7) for diagnostics, Life Science Services (23.8) for regulatory affairs. Remember: a manufacturing segment carries one activity, a non-manufacturing segment five.

Step 3. Check whether any activity is being taken from General Segment 26. If so, consult article 8.2 of the Decision: several activities, Medical Laboratory among them, require DHA or DHCA approval before the licence issues, and article 15 may impose a higher capital requirement.

Step 4. Budget AED 10,000 of capital and confirm that the chosen activity does not push the company into the General Segment table with its AED 50,000 or AED 500,000 thresholds.

Step 5. Choose the customs option under article 3.6. A free zone code requires goods to be stored within the bounded area; a local code triggers duty on arrival; no code makes import impossible.

Step 6. Size the premises from headcount, not the other way round. One visa per 80 square feet — and the same floor area does the work for the substance requirement in article 8 of Cabinet Decision No. 100 of 2023.

Step 7. Apply for the appropriate EDE licence — before registering any product. Marketing Office under article 106, Medical Warehouse under article 98, Pharmaceutical Laboratory under article 119, Biobank under article 140. Only an already-licensed establishment can be the applicant for a product registration.

Step 8. Register the product with the EDE and obtain its price. A marketing approval lasts five years, with renewal filed ninety days ahead. For a medical device: 45 working days, AED 100 plus AED 5,000.

Step 9. Obtain separate EDE approval for advertising and promotion, for each product. Valid from thirty days to one year.

Step 10. Where the activity touches patients, obtain a DHA facility licence and a licence for every professional. The two-key rule in article 7(a) of Resolution No. 49 of 2024.

Step 11. Model the tax position before operations begin. Manufacturing and processing produce qualifying income with no zone condition; distribution is unavailable; logistics is available only where title does not pass; R&D is not a qualifying activity; sales to individuals are an excluded activity.

Step 12. Choose between the 0% rate and the R&D tax credit — before the first application to the Emirates Research and Development Council. Article 3(2) of Cabinet Decision No. 215 of 2025 and the claw-back in article 16(2) of Ministerial Decision No. 24 of 2026 make combining them impossible.

Step 13. Where mainland sales are planned, take a branch under Resolution No. 11 of 2025, with prior DDA consent and separate records.

Common Mistakes and What They Cost

Mistake 1. Treating AED 25,000 and AED 15,000 as share capital requirements. They are the annual licence fees from the article 14 table; article 15 contains no Dubai Science Park capital table at all, and the residual AED 10,000 applies. Cost: over-subscribing capital is harmless in itself, but the error usually travels with an under-estimate of the real cost structure — fees across however many segments are needed, where a manufacturing segment yields one activity instead of five and each additional segment costs AED 10,000 a year.

Mistake 2. Assuming the DDA licence confers a right to sell medicines or devices. Article 2.15 of the DDA Decision and article 173 of Decree-Law No. 38 of 2024 each expressly disclaim exclusivity. Cost: circulating a medical product without EDE marketing approval attracts, under article 164(2), imprisonment of one to five years and a fine of AED 100,000 to AED 500,000.

Mistake 3. Looking for a “scientific office” licence. No such vehicle exists in either the English or the Arabic text. The statutory instrument is the Marketing Office under article 106, and it may not import or store medical products for sale or distribution (article 109). Cost: months spent on the wrong application type, and the risk that the activity actually carried on exceeds what the office is permitted to do.

Mistake 4. Building a distribution model around the “Distribution” qualifying activity. Article 2(1)(l) requires the activity to be “in or from a Designated Zone”, and Dubai Science Park is not on the Designated Zone list. Cost: once non-qualifying revenue exceeds the threshold — 5% of total revenue or AED 5,000,000, whichever is lower — Qualifying Free Zone Person status is lost from the beginning of that period and for the four periods that follow.

Mistake 5. Claiming the R&D tax credit while on the 0% rate. Article 3(2) of Cabinet Decision No. 215 of 2025 admits a Qualifying Free Zone Person only where it is taxed at 9% on income from the qualifying research activities or is within the Top-up Tax. Cost: beyond refusal of the credit, a claw-back of credit already used under article 16(2) of Ministerial Decision No. 24 of 2026 if Qualifying Free Zone Person status is acquired within five years of the end of the last claim period.

Mistake 6. Quoting penalty amounts from the English text of the federal law. Articles 160, 166 and 167 contain evident translation defects, and the English of article 140(1) sends a biobank application to the wrong regulator. Cost: an application filed with the Ministry instead of the Emirates Drug Establishment comes back, and a risk assessment built on inflated or understated figures misprices the project.

Mistake 7. Assuming that operating onshore from a free zone remains prohibited. Executive Council Resolution No. 11 of 2025 was issued on 3 March 2025 and takes effect on publication; the district’s own FAQ does not reflect the change. Cost: either a missed route onto the mainland, or mainland sales without a Department of Economy and Tourism licence — where article 13 gave existing operators only one year to regularise.

Mistake 8. Promising investors or partners GMP-ready premises at Dubai Science Park. The words “GMP”, “Good Manufacturing Practice”, “cleanroom” and “ISO class” appear on no official district or TECOM Group page, and the Laboratory Complex is described as shell and core. Cost: the gap between what was promised and what the space actually is emerges at the qualification stage, when the project timetable is already fixed.

Who Dubai Science Park Suits, Who It Does Not, and When Professional Review Is Needed

Dubai Science Park suits a company whose core UAE activity creates value inside the zone rather than reselling goods onto the mainland.

The location is a sound choice for:

•          manufacturers and processors of medicines, devices, specialty materials and ingredients — manufacturing and processing produce qualifying income with no Designated Zone condition;

•          regional headquarters of pharmaceutical and medtech groups — headquarter services to related parties are on the qualifying activities list;

•          third-party storage and logistics operators that do not take title to the goods;

•          diagnostics and research laboratories prepared for parallel DHA licensing;

•          marketing offices and regulatory-function holders — activity 23.8.5 expressly covers regulatory affairs services;

•          owners of patents, software and orphan drug designations using the qualifying intellectual property route.

The location is questionable for:

•          the classic importer-distributor selling onto the mainland — the “Distribution” qualifying activity is unavailable here;

•          companies with material sales to individuals — an excluded activity whatever the rest of the structure;

•          revenue-stage biotechs hoping to combine the 0% rate with the R&D tax credit;

•          projects needing GMP-ready space — the district does not claim it;

•          structures requiring multiple share classes or a public company form.

Professional review is warranted in the following situations.

Before incorporation — confirming the zone’s status for corporate tax purposes. No publicly issued list of free zones under Federal Decree-Law No. 47 of 2022 could be located, and guide CTGFZP1 refers the question back to the zone. Written confirmation from the DDA is worth obtaining beforehand, not afterwards.

When choosing between segment 23.7 and activity 26.2.8. The commercially similar “Diagnostics and Analysis” and “Medical Laboratory” lead to different approval procedures and different capital requirements.

When determining whether a product is a medical device. The definition captures wearable devices and AI-based products; the EDE’s class criteria are not published, and a device’s class should be confirmed by enquiry.

When structuring the research function. The choice between the 0% rate and the R&D credit is irreversible over a five-year horizon because of the claw-back rule.

When planning mainland sales. Prior DDA consent, a Department of Economy and Tourism licence and separate records are required — and the tax position of a domestic permanent establishment is modelled separately.

Frequently Asked Questions

Is Dubai Science Park a free zone?

Yes, as part of the Creative Clusters declared a free zone by Dubai Law No. 15 of 2014. The district itself, however, is named in no law or decree of the emirate: it is defined only in the subordinate DDA Decision No. 1 of 2021, where ‘“DSP” means the Dubai Science Park.’ No publicly issued Cabinet decision listing free zones for corporate tax purposes could be located, and the Federal Tax Authority advises confirming the status with the zone itself.

Who issues the licence in Dubai Science Park — the DDA or TECOM Group?

The Dubai Development Authority. Article 2.1 of Decision No. 1 of 2021: “Licences are issued by the Authority for each of DIC, DMC, DKP, DIAC, DPC, DOC, DSC, DSP and D3.” TECOM Group is the operator and landlord: the districts “are located and operated under the jurisdiction of Dubai Development Authority (DDA), which is in charge of company registration and licensing”.

What does a Dubai Science Park licence cost?

AED 15,000 a year for a non-manufacturing segment and AED 25,000 a year for a manufacturing one. A non-manufacturing segment carries five activities, a manufacturing one carries one. The Diagnostics and Analysis segment gives four activities for AED 15,000. An additional segment costs AED 10,000 a year, and a freelance permit AED 7,500 a year.

What is the minimum share capital in Dubai Science Park?

AED 10,000. That is the residual rule in article 15.1 of DDA Decision No. 1 of 2021, applying to every activity for which nothing else is specified. Article 15 contains no Dubai Science Park capital table. The figures AED 25,000 and AED 15,000 are annual licence fees, not capital requirements.

Does a Dubai Science Park licence permit the sale of medicines in the UAE?

No. Under article 5(1) of Decree-Law No. 38 of 2024 a medical product may not be imported, distributed, held, sold, displayed, used or manufactured without marketing approval from the Emirates Drug Establishment. Moreover, only an EDE-licensed establishment — a marketing office, a manufacturer, a contract manufacturer or a designated medical warehouse — can be the applicant for a product registration.

Does a Dubai Science Park company need a DHA licence?

Yes, if it delivers health services to patients. Article 7(a) of Executive Council Resolution No. 49 of 2024 requires the facility to be licensed “by the Concerned Entities and has obtained a Licence from the DHA”, and article 2(a)(1) extends the regime expressly to free zones. A distributor or a marketing office needs no DHA licence.

Is Dubai Science Park a Designated Zone for VAT?

No. The Designated Zone list published by the Federal Tax Authority under Cabinet Decision No. 59 of 2017 as amended through Cabinet Decision No. 81 of 2021 names nine Dubai zones, seven of them live. Dubai Science Park is not among them, nor is any other zone administered by the Dubai Development Authority.

Does VAT zero-rating apply to medicines sold from Dubai Science Park?

Yes. Cabinet Decision No. 56 of 2017 keys zero-rating to registration of the product, not to the supplier’s location: “The supply of Medications and Medical Equipment registered with the Ministry of Health and Prevention, or imported with its permission or approval, shall be subject to tax at zero rate.” The provision contains no free zone or Designated Zone condition.

Can a Dubai Science Park company obtain the 0% corporate tax rate?

Yes, on qualifying income — but the range of available qualifying activities is limited. Manufacturing, processing, holding of shares, headquarter services to related parties and logistics services are available. Distribution of goods is not, because it requires the activity to be “in or from a Designated Zone”. The de minimis threshold for non-qualifying revenue is 5% of total revenue or AED 5,000,000, whichever is lower.

Is research and development a qualifying activity?

No. Article 2(1) of Ministerial Decision No. 229 of 2025 lists fourteen activities, and research is not one of them. Income from research services is qualifying only where the recipient is a Free Zone Person that is the Beneficial Recipient — under article 3(1)(a) of Cabinet Decision No. 100 of 2023, which imposes no activity condition.

Can a company on the 0% rate claim the R&D tax credit?

No. Article 3(2) of Cabinet Decision No. 215 of 2025 admits a Qualifying Free Zone Person only where it is taxed at 9% on taxable income derived from the qualifying research activities, or is within the Top-up Tax. Further, acquiring Qualifying Free Zone Person status within five years of the end of the last claim period triggers a claw-back of credit already used, under article 16(2) of Ministerial Decision No. 24 of 2026.

Can a Dubai Science Park company operate on the Dubai mainland?

Yes. Executive Council Resolution No. 11 of 2025, issued 3 March 2025, allows a branch licence or an activity-specific permit from the Department of Economy and Tourism, subject to DDA consent and separate financial records. Article 12 sets a fee of AED 10,000 a year for a branch operating out of the free zone and AED 5,000 for a temporary permit of up to six months. The district’s own FAQ does not yet reflect this change.

How many visas can a Dubai Science Park company obtain?

One visa per 80 square feet of leased space. That is the operator’s rule; DDA Decision No. 1 of 2021 contains no visa provisions at all. The establishment card is issued by the General Directorate of Residency and Foreigners Affairs in Dubai; the issuance fee is AED 200 plus VAT, and renewal is AED 100 a year.

Key Takeaways

•          Dubai Science Park is one of ten districts licensed by the Dubai Development Authority under its Decision No. 1 of 2021. TECOM Group is the operator; the DDA issues the licence.

•          The district is named only in DDA subordinate legislation. Neither Law No. 15 of 2014 nor Law No. 8 of 2023 names any district; the schedule to Law No. 8 of 2023 carries land plot numbers only.

•          Dubai Science Park is the only district with two Parts in the Decision: Segment 23 (life sciences) and Segment 24 (energy and environment).

•          The annual fee is AED 15,000 for a non-manufacturing segment (five activities) and AED 25,000 for a manufacturing one (a single activity). An additional segment costs AED 10,000 a year.

•          Minimum paid-up capital is AED 10,000. Article 15 contains no Dubai Science Park capital table; AED 25,000 and AED 15,000 are licence fees.

•          The DDA licence substitutes for neither the federal nor the emirate health licence. Article 2.15 of the DDA Decision and article 173 of Decree-Law No. 38 of 2024 each expressly disclaim exclusivity.

•          The Emirates Drug Establishment registers products, licenses pharmaceutical establishments, sets prices and issues import permits across the UAE, free zones included. The operational transfer from the Ministry of Health took place on 31 December 2025: 44 services moved fully, 13 partially, and 5 remained with the Ministry.

•          There is no “scientific office” in the statute — there is a Marketing Office under article 106, which may not import or store medical products for sale or distribution.

•          The DHA licenses facilities and professionals across every zone in the emirate, free zones included; the two-key rule is article 7(a) of Resolution No. 49 of 2024. Since 2024 Dubai Healthcare City confers no separate health-regulatory regime.

•          Dubai Science Park is not a Designated Zone for VAT, but zero-rating of registered medicines and devices does not depend on that — it attaches to product registration, not to the supplier’s location.

•          The qualifying activities available to the district are manufacturing, processing, holding of shares, headquarter services to related parties, and logistics without taking title. Distribution of goods is not available.

•          Research and development is not a qualifying activity, while the qualifying intellectual property route expressly includes orphan drug designations and protection for genetic material.

•          The 0% rate and the R&D tax credit are mutually exclusive under article 3(2) of Cabinet Decision No. 215 of 2025, and acquiring Qualifying Free Zone Person status within five years triggers a claw-back of credit already used.

•          Operating on the Dubai mainland is possible under Executive Council Resolution No. 11 of 2025, issued 3 March 2025 — with DDA consent, a Department of Economy and Tourism licence and separate records.

Summary 

Dubai Science Park is one of ten TECOM Group districts licensed by the Dubai Development Authority under DDA Decision No. 1 of 2021, in which the district is defined as “DSP” and is the eighth of ten; the emirate’s own laws — Law No. 15 of 2014 and Law No. 8 of 2023 — name no district at all. The district’s activity schedules occupy Part Eight (Segment 23, life sciences: Therapeutics, Food, Agricultural, Environment, Medical/Scientific Devices or Equipment, Specialty Supplies, Diagnostics and Analysis, Life Science Services, Life Science Associations, Conformity Assessment) and Part Nine (Segment 24, energy and environment). The annual licence fee is AED 15,000 for a non-manufacturing segment carrying five activities and AED 25,000 for a manufacturing segment carrying one; an additional segment costs AED 10,000 a year; a freelance permit AED 7,500 a year; and minimum paid-up share capital is AED 10,000 under the residual rule in article 15.1. The DDA licence confers no right to deal in medical products: article 5(1) of Federal Decree-Law No. 38 of 2024, in force since 2 January 2025, requires marketing approval from the Emirates Drug Establishment, created by Federal Decree-Law No. 28 of 2023, with the operational transfer from the Ministry of Health completed on 31 December 2025. Registering a medical device takes 45 working days and costs AED 100 plus AED 5,000, marketing approval lasts five years, an import permit is required for every consignment, and the import fee is 1% of invoice value. Healthcare facilities and professionals in Dubai Science Park are licensed by the Dubai Health Authority under article 7(a) of Executive Council Resolution No. 49 of 2024, which reaches free zones expressly. Dubai Science Park is not on the VAT Designated Zone list, but zero-rating of registered medicines and devices under Cabinet Decision No. 56 of 2017 does not depend on zone status. For corporate tax the district can reach the qualifying activities of manufacturing, processing, holding of shares, headquarter services to related parties and logistics services, but not distribution of goods, which requires a Designated Zone; research and development is absent from the fourteen qualifying activities in article 2(1) of Ministerial Decision No. 229 of 2025, and the R&D tax credit under Cabinet Decision No. 215 of 2025 is unavailable to a company taxed at 0%.

The regulatory perimeter of a life-sciences project in Dubai is made of three licences, and the cost of getting the entry wrong exceeds the cost of checking. UPPERSETUP advises on company registration in the UAE and on all three layers — zone, federal and emirate; the site’s profile of the location itself is on the Dubai Science Park page.

Sources

Level 1 — Dubai emirate legislation

•          Dubai Law No. 15 of 2014 — portal status: “In Force as Amended”

•          Dubai Law No. 8 of 2023 amending Law No. 15 of 2014

•          Decree No. 28 of 2023 allocating land plots

•          Executive Council Resolution No. 11 of 2025 on free zone establishments’ activities within the emirate

•          Dubai Law No. 6 of 2018 concerning the Dubai Health Authority

•          Executive Council Resolution No. 49 of 2024 on health professions and health activities

•          Administrative Resolution No. 25 of 2025 approving the manuals and protocol

•          Dubai Law No. 16 of 2024 concerning Dubai Healthcare City

•          Dubai Law No. 5 of 2025 concerning public health

Level 1 — Dubai Development Authority instruments and materials

•          DDA Decision No. 1 of 2021 concerning licence categories — 136 pages

•          Dubai Creative Clusters Private Companies Regulations 2016

•          DDA — Laws & Regulations

•          DDA — archive of superseded regulations

•          DDA — TECOM Group and the list of districts

Level 1 — UAE federal legislation

•          Federal Decree-Law No. 38 of 2024 governing medical products, pharmacists and pharmaceutical establishments

•          Federal Decree-Law No. 28 of 2023 establishing the Emirates Drug Establishment

•          Cabinet Resolution No. 90 of 2021 — Executive Regulation to Federal Law No. 8 of 2019 — preserved by article 180(2) of Decree-Law No. 38 of 2024

•          Cabinet Resolution No. 40 of 2025 on fees for Emirates Drug Establishment services

•          Federal Decree-Law No. 47 of 2022 on the taxation of corporations and businesses — consolidated text

Level 1 — tax instruments and guidance

•          Cabinet Decision No. 100 of 2023 on qualifying income for the Qualifying Free Zone Person

•          Ministerial Decision No. 229 of 2025 on qualifying and excluded activities

•          Cabinet Decision No. 215 of 2025 on the R&D tax credit

•          Ministerial Decision No. 24 of 2026 implementing Cabinet Decision No. 215 of 2025

•          Federal Tax Authority Decision No. 6 of 2026 on additional procedures for Qualifying Free Zone Persons engaged in Designated Zone distribution

•          Free Zone Persons — Corporate Tax Guide, CTGFZP1, May 2024

•          Federal Decree-Law No. 8 of 2017 on VAT and its amendments — consolidated text

•          Executive Regulation of the VAT Law — consolidated text of 18 September 2025

•          Cabinet Decision No. 56 of 2017 on medications and medical equipment subject to tax at zero rate

•          Federal Tax Authority list of Designated Zones

•          Federal Tax Authority legislation register

Level 1 — regulators and government portals

•          Emirates Drug Establishment — marketing authorisation for a medical device

•          Emirates Drug Establishment — licensing of a marketing office

•          Emirates Drug Establishment — licensing of a medical warehouse

•          Emirates Drug Establishment — legislation

•          Ministry of Health and Prevention — transfer of services to the Emirates Drug Establishment

•          WAM — report on the transfer of services, 31 December 2025

•          Dubai Health Authority — Manual for Licensing Health Facility, version 1.1

•          GDRFA Dubai — establishment card for the private sector and free zones

•          UAE government portal — tax incentives for innovation-driven businesses

•          UAE Ministry of Finance — launch of phase 1 of the R&D tax incentives programme

Level 1 — official Dubai Science Park and TECOM Group materials

•          Dubai Science Park — FAQs

•          Dubai Science Park — Laboratory Complex

•          Dubai Science Park — warehouses

•          Dubai Science Park — storage and logistics facilities

•          Dubai Science Park — light industrial units

•          Dubai Science Park — twentieth anniversary release, 5 February 2026

•          Dubai Science Park and the Emirates Drug Establishment — forum, 25 June 2026

•          TECOM Group — storage expansion release, 5 June 2024

•          TECOM Group PJSC — 2025 results, 3 February 2026

Notes on Verification

The texts of DDA Decision No. 1 of 2021 and of the 2016 Private Companies Regulations were extracted programmatically from the Dubai Development Authority’s own PDFs. Both are published as PDFs with subset fonts; the text was decoded through the files’ embedded ToUnicode tables, yielding the documents’ own characters rather than an optical-recognition result. Every fee and capital figure was checked against the tables in articles 14 and 15.

Levels of confirmation, distinguished. Instrument titles, numbers and dates, article numbers, licence fees and capital figures, segment and activity lists, tax rates, thresholds and deadlines are confirmed from primary texts. Area figures, laboratory counts and headcounts come from official Dubai Science Park and TECOM Group press releases, each cited with its date. Emirates Drug Establishment service timelines and fees come from its own published service descriptions rather than from the schedules to Cabinet Resolution No. 40 of 2025, which could not be obtained in machine-readable form.

On divergences between the English and Arabic texts. The UAE and Dubai legislation portals attach a disclaimer that the Arabic prevails. Decree-Law No. 38 of 2024 contains material divergences: the English of article 140(1) names the Ministry as the licensing authority for biobanks where the Arabic names the Emirates Drug Establishment; the English of article 2(1) introduces the qualifier “Hazardous Medical Products”, absent from the Arabic; and articles 160, 166 and 167 carry evident defects in their penalty figures. All sanction amounts in this article are taken from the Arabic text.

On divergences between the instruments and the operator’s materials. The Dubai Science Park FAQ diverges from DDA Decision No. 1 of 2021 in two places. First, the operator offers a freelance permit, whereas the freelancer segments in article 2.9 are confined to segments 16.5, 18.9, 21.13 and 25.10, and the Dubai Science Park fee table contains no Freelancer row. Second, the operator answers “yes” to a question about a “scientific office”, citing a memorandum with the Ministry of Health, whereas no such vehicle appears in either the English or the Arabic text of Decree-Law No. 38 of 2024. Both divergences are resolved in this article in favour of the instruments, and both are flagged expressly.

On divergences between official sources of the same rank. Dubai Science Park’s storage area is given as 336,000 sq ft in the June 2024 release and as “more than 330,000 sq ft” in the February 2026 release; both are cited with their dates. The district’s warehouse page contradicts itself: the prose gives a range from 6,000 sq ft, the specification list from 6,400 sq ft; the latter is used, matching the separate specification page. The district’s customer count — “more than 500” — dates from June 2024 and is not repeated in the 2026 materials. The headcount of “more than 6,500” appears unchanged in both the June 2024 and the February 2026 releases, while the district’s retail page gives “3600+ professionals”; the divergence is flagged in the text.

What could not be confirmed. The Laboratory Complex’s floor area, its number of units and its opening date are not published. GMP readiness, cleanrooms and cold-chain parameters are not claimed in any official source; the only relevant wording is “cold, chemical & general” in the warehouse suitability list. No 2026 customer count for the district is published. No publicly issued Cabinet decision listing free zones for corporate tax purposes could be located; guide CTGFZP1 refers the question back to the zone. No Executive Regulation to Decree-Law No. 38 of 2024 appears on the UAE legislation portal or on the Emirates Drug Establishment’s legislation page. No Cabinet resolution extending the one-year regularisation period under article 175 of Decree-Law No. 38 of 2024, which expired on 2 January 2026, could be located. No published criteria for assigning a medical device to classes I to IV could be found. The Emirates Research and Development Council’s pre-approval timeline under article 4(1) of Ministerial Decision No. 24 of 2026 is set by the Council itself and is not publicly stated.

On documents not treated as current law. Federal Law No. 8 of 2019 was repealed by article 180 of Decree-Law No. 38 of 2024 and is cited only as a repealed instrument. The Dubai Science Park FAQ, in so far as it states that operating outside the zone is prohibited, contradicts Executive Council Resolution No. 11 of 2025 and is not used as a source for the current position. Guide CTGFZP1 was issued in May 2024, before Ministerial Decision No. 229 of 2025 and Federal Tax Authority Decision No. 6 of 2026; its treatment of qualifying activities is framed on the repealed Ministerial Decision No. 265 of 2023 and is not used for that purpose here. No consultancy, company-formation or aggregator publication was used as a source.

Information current as at August 2026.

Disclaimer

This material is provided for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before making any decision, individual professional advice should be obtained, taking into account the specific situation, jurisdiction, status of the company and the current requirements of the relevant regulators.

Published: August 2026.