Dual license Dubai, mainland routes for a free zone company

Key Takeaways

Resolution 11 of 2025 gives Dubai free zone companies three mainland routes: a mainland branch, a branch operating out of the zone, or a permit.
The branch out of the free zone costs AED 10,000 a year; the permit costs AED 5,000 for up to six months (October 2026).
Every route needs your free zone authority's prior approval first, and the permit also needs a Dubai Unified Licence.
Mainland revenue is taxed at 9% and needs separate books; it can also cost Qualifying Free Zone Person status.
The routes cover Dubai only; other emirates need their own licences (Article 3(c)).

A dual license in Dubai, as the market uses the phrase, is the branch operating out of the free zone that Executive Council Resolution 11 of 2025 lets a free zone company hold. It is one of three routes for an owner with Dubai customers, and the choice between them turns on cost, permanence and what must be approved first.

What changed in 2025 and who it applies to

Resolution 11 of 2025, issued on 3 March 2025, lets Dubai free zone establishments conduct activities outside their zone, within Dubai, through a licence or a permit. It does not apply to financial establishments licensed in DIFC (Article 2).

Before it, a few zones ran their own dual-licence arrangements with the Dubai department. One law firm names DIFC, DAFZA, DMCC and Dubai Design District, under agreements dated 2017 to 2020 (law-firm briefing, March 2025). The Resolution set one framework for Dubai free zone companies, apart from DIFC financial establishments.

The three routes and their fees

The Resolution fixes a fee for two of the three routes, and the mainland-premises branch follows DET's general fee rules.

Route	Basis	Fee	Validity
Branch within the emirate, on mainland premises	Article 4(a)(1)	Not fixed by the Resolution; DET's general fee rules apply	1 year, renewable
Branch operating out of the free zone (the dual licence)	Article 4(a)(2)	AED 10,000 a year to issue or renew	1 year, renewable
Temporary permit	Article 7	AED 5,000 to issue or renew	Up to 6 months

Fees come from Article 12 and from the Dubai Media Office release of 8 October 2025, as of October 2026. Some summaries apply the AED 10,000 to both branch types, but the text fixes it only for the branch operating out of the free zone. Two six-month permits, 2 x AED 5,000, come to AED 10,000, the same as one year of the branch fee, so the choice turns on scope and permanence as well as price.

What the free zone and DET each must approve

Your free zone's licensing authority approves first, and DET issues the licence or permit. Every route needs a valid free zone licence, the zone's prior approval and, for regulated activities, the sector regulator's approval. A branch has no separate legal personality. For the branch out of the zone, DET asks for a copy of the memorandum, the free zone licence and the manager's passport and Emirates ID (Article 6).

Permits are limited to activities on DET's list, which Article 9 required DET and the zone to publish within six months. Ask DET for the current list for your activity. At launch the Free Zone Mainland Operating Permit covered non-regulated activities such as technology, consultancy, design, professional services and trading, with regulated sectors planned for later. Applicants need a Dubai Unified Licence (DUL), which DET launched on 11 December 2023, and apply through Invest in Dubai.

Companies already trading on the mainland had one year from the Resolution's effective date to comply, with one possible extension of the same length at the Director General's discretion (Article 13). Ask DET where your company stands.

Separate books and the 9% Corporate Tax effect

Article 3(b)(2) requires mainland activity to keep its own financial records, and the Dubai Media Office states that its revenue is subject to 9% Corporate Tax. Articles 10 and 11 apply Dubai legislation and penalties and allow audit and inspection by DET and the zone.

Wider effects sit in the Qualifying Free Zone Person (QFZP) test. If non-qualifying revenue exceeds the lower of 5% of total revenue or AED 5,000,000, the company loses QFZP status for that period and the next four (Ministerial Decision 229 of 2025). Ordinary services sold to mainland customers are generally non-qualifying. Modelling that before the first invoice is a job for a corporate tax consultant.

The common failure is selling to mainland customers with no branch licence or permit, and keeping one set of books for everything. Dubai legislation and penalties then apply (Articles 10 and 11).

Other emirates need their own licence

Neither a Dubai licence nor a Dubai permit works in Abu Dhabi or Sharjah. Article 3(c) requires the licences and permits of the competent entity in the other emirate. Abu Dhabi, for example, runs its own ADDED Dual Licence for Abu Dhabi free zone companies (October 2026). The Company Setup UAE hub and the mainland company guide cover the other departments.

Questions to settle before you sell on the mainland

Is the customer in Dubai, and is the activity on DET's list or regulated?
Which route fits: a branch operating out of the free zone at AED 10,000 a year or a permit at AED 5,000 per six months?
Has the free zone approved, and what does it charge?
Is a DUL in place, and can you keep separate books?
What is the 9% effect on your QFZP status?

Cost and tax decide the choice, so a written opinion from a lawyer or licensed adviser before the first mainland invoice is worth having. The free zone company guide compares the zones themselves.

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Frequently Asked Questions

What is a dual licence in Dubai?

In current use it means the branch operating out of the free zone under Executive Council Resolution 11 of 2025, which costs AED 10,000 a year to issue or renew. Before 2025 the phrase also described older arrangements between a few zones and the Dubai department.

Can a free zone company work on the Dubai mainland?

Yes, in Dubai only, through one of three routes under Resolution 11 of 2025: a mainland branch, a branch operating out of the free zone or a temporary permit. Each needs your free zone's prior approval, and DET issues the licence or permit.

How much is the Free Zone Mainland Operating Permit?

It costs AED 5,000 for six months and renews at the same fee every six months (Dubai Media Office, 8 October 2025). It needs a Dubai Unified Licence, is applied for through Invest in Dubai, and initially covers non-regulated activities.

Does a Dubai permit let me trade in Abu Dhabi or Sharjah?

No. Neither the Dubai branch nor the Dubai permit works outside Dubai, because Article 3(c) of Resolution 11 of 2025 requires the licences and permits of the competent entity in the other emirate. Abu Dhabi runs its own ADDED Dual Licence for its free zone companies.

Do I pay 9% Corporate Tax on mainland income?

Yes, mainland-related revenue is subject to 9% Corporate Tax and needs separate records (Dubai Media Office). Large amounts of non-qualifying revenue can also cost Qualifying Free Zone Person status for that tax period and the next four.

Does Resolution 11 of 2025 apply to DIFC companies?

Not to financial establishments licensed in DIFC (Article 2). Other DIFC companies are not excluded by that article, so confirm your position with DET and the DIFC registrar before you rely on either.