Table of Contents
- Dubai Dual Licence: The Short Answer
- What Resolution 11 of 2025 Changed
- The Three Routes Compared
- Who Can Apply for a Dubai Dual Licence
- How the Application Works
- What a Dubai Dual Licence Costs
- Dubai Dual Licence and Qualifying Free Zone Person Status
- A Worked Tax Example
- Which Route Fits Your Business
- Deadlines and Mistakes to Avoid
- Limits of This Article
- FAQ
- Your Next Step
Dubai Dual Licence: The Short Answer
A Dubai dual licence lets a free zone company sell to mainland customers without giving up its free zone base. Since Dubai Executive Council Resolution No. 11 of 2025, you no longer need an agent or a separate mainland company just to invoice a mainland client.
There are three routes: a mainland branch or subsidiary, a mainland branch run from your free zone office (the route the market calls the Dubai dual licence), and a temporary permit. Each needs approval from the Dubai Department of Economy and Tourism (DET) and your free zone authority.
The catch is tax. Mainland activity usually becomes a taxable presence at 9%, and it must be kept in separate accounts. Used well, a Dubai dual licence can protect your free zone tax status. Used badly, it can cost you that status.
This guide explains the three routes, who qualifies, what the fees are and where costs vary by zone. It also covers how mainland income interacts with Qualifying Free Zone Person status. If you are still deciding between the two markets, start with our free zone vs mainland comparison.
What Resolution 11 of 2025 Changed
The full title is Executive Council Resolution No. (11) of 2025 Regulating the Conduct of Free Zone Establishments’ Activities within the Emirate of Dubai. It was published in the Official Gazette on 3 March 2025, according to KPMG’s summary of Resolution No. 11 of 2025.
Before it, a free zone company could trade only inside its zone. To reach mainland customers it had to appoint a third-party agent, register a branch or set up a separate onshore company. Each option added cost, paperwork or a loss of control over the relationship.
The Resolution gives free zone companies a lawful way to operate on the Dubai mainland while keeping their free zone licence. The term “dual licence” is market shorthand, not the Resolution’s wording. In practice a Dubai dual licence means a branch licence from DET while your head office stays in the free zone.
Three limits matter from the start:
- It covers only the Emirate of Dubai. No route lets you trade in another emirate.
- It applies to non-financial entities. Financial entities in the Dubai International Financial Centre (DIFC) are excluded.
- You can keep your existing free zone employees for mainland work, according to KPMG and the Dubai Media Office.
The Three Routes Compared
The table below summarises the three routes using the fees published by KPMG and Afridi & Angell. Fees change, so confirm the current figure with DET and your free zone before you budget.
| Route | What it is | Validity | Government fee |
|---|---|---|---|
| 1. Mainland branch or subsidiary | A branch of the free zone company, or a new company, based in mainland Dubai | 1 year, renewable | AED 10,000 a year per KPMG; existing branch fees apply per Afridi & Angell |
| 2. Dubai dual licence (branch from the free zone) | A mainland branch operating from a registered office in the free zone | 1 year, renewable | AED 10,000 a year |
| 3. Temporary permit | Specific activities on the mainland for a limited time | Up to 6 months | AED 5,000 |
Route 1 is the heaviest. You need a mainland office and the full branch or company set-up. Our branch vs subsidiary comparison explains how those structures differ in liability and tax.
Route 2 is the Dubai dual licence in the strict sense. You keep one head office in the free zone and add a mainland branch licence on top of it. The Resolution describes it as a branch operating from a registered office in the free zone, but check what DET and your free zone require in your case.
Route 3 is the lightest. It suits a short project or a market test. The Dubai Media Office describes the Free Zone Mainland Operating Permit as costing AED 5,000, valid for six months and renewable at the same fee.
Who Can Apply for a Dubai Dual Licence
Eligibility has four layers. You need to pass each one.
- Entity type: a non-financial entity licensed by a free zone authority in Dubai. DIFC financial entities are excluded.
- Licence: for the permit route, the Dubai Media Office says the company must hold a Dubai Unified Licence (DUL).
- Activity: your activity must be on the DET list of eligible activities. The list also says which activities need a branch licence and which can use a permit.
- Regulator: a regulated activity needs approval from its supervising authority as well.
The Dubai Media Office states that the first phase of the permit covers non-regulated activities such as technology, consultancy, design, professional services and trading. It says regulated sectors are planned for later. I could not find the full DET activity list, so check it with your free zone before you plan.
If your activity is not eligible, a conventional mainland company may be the only lawful route. A short call with an adviser at that point saves months of waiting.
How the Application Works
The exact steps differ by zone, but the sequence is consistent in the published summaries. Both KPMG’s summary of Resolution No. 11 of 2025 and Afridi & Angell’s note on the Resolution describe approval by DET and by other authorities that supervise the activity.
- Check eligibility. Match your licensed activity to the DET list and confirm whether you need a branch licence or a permit.
- Ask your free zone authority. Request its approval or no-objection letter. Prior approval is required.
- Prepare documents. Expect your trade licence, company documents and details of the activity.
- Apply to DET. The permit is applied for online through the Invest in Dubai platform, according to the Dubai Media Office.
- Pay the fees. The government fee is payable with the application.
- Set up separate accounting. Keep mainland records apart from free zone records from day one.
Do not start mainland trading until the licence or permit is issued. Invoicing mainland customers while an application is pending is the most common way to create a compliance problem.
What a Dubai Dual Licence Costs
The published government fees are small: AED 10,000 a year for a branch and AED 5,000 for a temporary permit. The real cost of a Dubai dual licence is higher, because several items sit outside those two numbers.
| Cost item | Fixed or variable |
|---|---|
| DET government fee (branch or permit) | Published: AED 10,000 or AED 5,000 |
| Free zone approval or no-objection letter | Varies by free zone |
| Free zone licence renewal while the branch runs | Varies by free zone |
| Typing, service and agent fees | Varies by provider |
| Regulator approval for regulated activities | Varies by regulator |
| Separate bookkeeping and tax filings | Varies by volume |
| Corporate tax on mainland profit | 9% on taxable income, subject to the rules |
I am not quoting totals, because zones price their approvals and renewals differently. Ask your free zone and any provider for an itemised written quote. Compare it with the cost of a full mainland company, which usually adds office space, visas and a separate renewal cycle.
If you want a side-by-side budget, our team can price all three routes for your activity through our business setup service.
Dubai Dual Licence and Qualifying Free Zone Person Status
This is the part most consultancy pages skip. A free zone company that meets the conditions pays 0% corporate tax on qualifying income and 9% on the rest. Mainland sales sit uncomfortably with that regime.
The Dubai Media Office states that mainland revenue earned under the permit is subject to 9% corporate tax, and that companies must keep separate financial records that meet Federal Tax Authority requirements. KPMG also stresses planning financial segregation in advance.
Our Qualifying Free Zone Person guide explains the detail. In short, a mainland branch of a free zone head office is a domestic permanent establishment. Its income is taxed at 9%, whatever the free zone says. The same guide notes that revenue attributable to a permanent establishment is left out of the de minimis calculation.
That matters because of the de minimis rule. Non-qualifying revenue must stay within the lower of AED 5,000,000 or 5% of total revenue, according to Ministerial Decision No. 229 of 2025 as described in that guide. A free zone company that sells to mainland customers without a licence can breach that limit quickly.
So a Dubai dual licence does not reduce your tax on mainland profit. What it does is move the mainland activity into a visible, separate and lawful channel. Whether the permit route also creates a permanent establishment depends on the facts, so test it against our permanent establishment rules guide.
A Worked Tax Example
This is my own illustration, not an official figure. Assume a free zone consultancy with AED 10,000,000 of revenue in a tax period.
| Step | Without a licence | With a Dubai dual licence |
|---|---|---|
| Mainland sales | AED 800,000 invoiced from the free zone | AED 800,000 booked through the mainland branch |
| De minimis limit (5% of revenue) | AED 500,000 on AED 10,000,000 | Branch revenue is left out of both sides of the test |
| Position on the test | AED 800,000 of non-qualifying revenue exceeds AED 500,000 | Rest of the free zone revenue is tested without it |
| Consequence | Qualifying Free Zone Person status is at risk for the period and the following years | Branch profit taxed at 9%; free zone qualifying income can stay at 0% |
The result depends on whether the rest of the company still meets every other condition, including substance and qualifying activities. Run the numbers with your adviser using real contracts, not averages. Our Qualifying Free Zone Person status article lists the five tests.
Which Route Fits Your Business
Use these questions to decide between the three routes.
| Your situation | Usual fit |
|---|---|
| One short project or a market test of three to six months | Temporary permit |
| Regular mainland clients, but your team and office stay in the free zone | Dubai dual licence |
| You need a shopfront, a mainland office or local staff of your own | Mainland branch or subsidiary |
| Your activity is regulated and not yet on the permit list | Ask the regulator; a mainland company may be needed |
| You want to trade in other emirates too | Separate licensing in each emirate |
If mainland trade will become your main business, a mainland company may fit better than a Dubai dual licence. The free zone benefits then matter less than the cost of running two sets of books.
Deadlines and Mistakes to Avoid
The Resolution took effect on 3 March 2025. According to KPMG, free zone companies already operating on the mainland had one year to comply, with a possible extension for another year. The first window therefore closed on 3 March 2026. Check with DET whether an extension applies to you.
Failure to comply may bring penalties under applicable legislation, according to KPMG. I did not find a published penalty scale, so I do not quote one.
Common mistakes to avoid:
- Invoicing mainland clients from the free zone and calling it export or consulting income.
- Applying for a permit and letting it lapse while contracts continue.
- Mixing mainland and free zone transactions in one ledger.
- Assuming the Dubai dual licence covers Abu Dhabi, Sharjah or other emirates.
- Ignoring the de minimis test until the audit.
Before you apply, read the Resolution’s exclusions and your free zone’s own conditions. Our business setup service team can map them to your activity.
Limits of This Article
I read the summaries by KPMG and Afridi & Angell, the Dubai Media Office announcement of 8 October 2025, and our own Qualifying Free Zone Person guide. I did not read the Resolution’s Arabic or English official text, and I could not find the DET activity list.
The two law-firm summaries differ on the route 1 fee, so I show both. Penalties, free zone charges and tax treatment of the temporary permit are not confirmed here. This is general information, not legal or tax advice. Have a UAE-qualified adviser check your facts before you apply.
FAQ
What is a Dubai dual licence?
A Dubai dual licence lets a free zone company keep its free zone licence and also hold a Dubai mainland branch licence, so it can trade directly with mainland customers. Under Resolution No. 11 of 2025 it is a branch operating from a registered office in the free zone, approved by DET and the free zone authority.
How much does a Dubai dual licence cost?
The government fee listed by KPMG for the branch operating from the free zone is AED 10,000 a year, and a temporary permit is AED 5,000 for up to six months. Free zone approval charges, service fees, accounting and any regulator fees are extra and vary by zone, so ask for written quotes.
Can any free zone company get a Dubai dual licence?
Not every company. The Resolution covers non-financial entities licensed in Dubai free zones and excludes financial entities in DIFC. Your activity must also appear on the DET list of eligible activities, and regulated activities need approval from their sector regulator. Start by asking your free zone authority for a no-objection letter.
Does a Dubai dual licence affect Qualifying Free Zone Person status?
It can protect it. Mainland activity run through a branch is usually treated as a domestic permanent establishment taxed at 9%, and its revenue is left out of the de minimis test. Mainland sales made without a licence are non-qualifying revenue and can breach the limit. Get tax advice on your facts.
Can I trade in Abu Dhabi or Sharjah with a Dubai dual licence?
No. The Resolution only covers the Emirate of Dubai. A free zone company that wants to trade in another emirate must obtain the licences and permits that emirate’s authorities require. Treat each emirate as a separate licensing decision and check its rules before you sign contracts there.
How long does a Dubai dual licence last?
The branch licence is valid for one year and renewable. The temporary permit lasts up to six months and renews at the same fee under the permit scheme announced in October 2025. Diary both renewal dates, because trading on the mainland with an expired licence or permit puts you back in breach.
Is a temporary permit better than a Dubai dual licence?
It depends on how long and how often you trade. A temporary permit suits a short project or a market test. If you serve mainland customers all year, the one-year branch licence is usually simpler and cheaper than renewing permits. Compare both against your expected mainland revenue before choosing.
Your Next Step
Want to sell to mainland clients without putting your free zone tax position at risk? Ask us to compare the three routes for your activity. Our set up the right Dubai structure for your free zone company, from the approvals to the separate accounting.
