What happened:
Dubai’s Executive Council issued Decision No. 11 of 2025, creating a pathway for free-zone entities to carry out activities outside their zone and inside Dubai’s mainland by obtaining a permit/license from the Department of Economy & Tourism (DET). Media summaries (Gulf News, Khaleej Times, Zawya/Arabian Business) and legal briefings confirm the change and its intent: simplify cross-jurisdiction operations and enable bidding for local work without creating a separate mainland company.
Who issues it:
DET via its Business Registration & Licensing arm (DBLC). Wording in press reports calls it a “permit/license” for free-zone companies to operate onshore; financial firms licensed by DIFC are expressly outside scope.
What it does (at a high level):
Lets a qualifying free-zone company conduct specified mainland activities under DET authority, without incorporating a separate onshore LLC.
Complements earlier MoUs/initiatives that allowed “dual licensing”, but this is a formal Executive Council framework rather than one-off arrangements.
The regime sits alongside Dubai’s push for easier market access and transparent oversight across zones and onshore markets.
Key guardrails and open questions
1) Scope and exclusions
DIFC-regulated financial institutions are out. VARA-regulated virtual asset activities are not mentioned explicitly in the decision summaries; applicants in that sector should expect additional scrutiny/conditions.
Press and legal analyses indicate not all activities will be permitted; DET will publish eligible activity lists and conditions per sector. (Expect limits around regulated professions, retail premises, and certain consumer-facing trades.)
2) Corporate tax impact (0% Free-Zone rate risks)
If you rely on the 0% rate as a Qualifying Free Zone Person, doing mainland activities can jeopardize that status unless they are qualifying activities and you respect the de-minimis rules on non-qualifying mainland income. In short: tax planning must be reviewed before applying for the permit. (This isn’t in the Decision itself, but flows from the UAE Corporate Tax regime’s QFZP rules).
3) VAT, customs & invoicing
Mainland supplies are standard-rated for VAT unless an exemption applies; invoices must meet FTA rules and e-invoicing phases as they roll out. (Not addressed in the Decision; standard UAE VAT rules apply.)
4) Labour & premises
Expect DET to require clarity on where staff perform work, tenancy/Ejari where relevant, and alignment with MOHRE work permits for onshore activity. Some activities may still require a mainland site or approved client premises.
5) Process & documentation
Law-firm commentaries outline a practical track: apply to DET/DBLC, evidence your free-zone licence, select permitted onshore activities, meet any sector add-ons, and maintain dual compliance (free zone + DET). Fees/validity to be set per activity.
Practical use-cases we’re already seeing
Bidding on Dubai government/large corporate RFPs where onshore licensing was a prerequisite.
Service firms (advisory, tech, B2B) with a free-zone parent that want to execute contracts at client premises in mainland Dubai.
Light trading/installation where goods are imported via a free zone but commissioning happens onshore under one contracting entity.
Common misreads to avoid
“We can sell anything anywhere now.” No activities are permissioned. Check DET’s activity list and sector conditions.
“This replaces a mainland company.” It may, for some models, but not for retail footprint, certain regulated services, or where counterparties still insist on an onshore CR.
“Tax stays 0% regardless.” Not if the activity is non-qualifying or breaches de-minimis thresholds for QFZP status. Model this first.
A quick readiness checklist
Map activities & contracts: Which onshore activities do you truly need? Are they on DET’s permitted list?
Tax modelling: Test QFZP eligibility under multiple revenue mixes; ring-fence non-qualifying income if needed.
Contracting & invoicing: Update terms to reflect mainland execution, VAT treatment, governing law, and venue.
People & premises: Align MOHRE permits, insurance, and (if required) mainland workspace or client-site approvals.
Governance: Ensure board resolutions cover the DET permit, banking mandates, and compliance reporting.
Our take for African founders and family offices
For groups operating across Dubai + Africa, this is a rare window to simplify structures: keep your holding and treasury in a free zone, add a DET permit for targeted mainland delivery, and avoid duplicative entities – if the tax and activity rules work in your favor. It’s also a cleaner way to meet RFP eligibility without rushing into an onshore CR.
Sources you can rely on (English & Arabic)
Gulf News: summary of the Decision, scope and exclusions (DIFC).
Khaleej Times: overview of the framework and expected benefits.
Zawya/Arabian Business: business impact angle and DET role.
Mubasher (Arabic): cites Executive Council Decision No. 11 of 2025 and the headline provisions.
BLK Partners (legal note): procedural insights & compliance considerations under the Decision.
How we can help (fast)
Permit strategy: Determine whether the DET permit genuinely replaces an onshore entity for your model.
Tax & compliance: Preserve 0% Free-Zone treatment where possible; structure contracts and flows to avoid de-minimis breaches.
Application pack: Activity selection, supporting documentation, governance (board resolutions), and bank/ERP alignment.
Roll-out: HR, MOHRE, VAT invoicing, and client-side onboarding for mainland execution.
If you want a clean, bank-friendly and tax-robust setup for onshore delivery without over-building, we’ll map it and execute.