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

1. Map activities & contracts: Which onshore activities do you truly need? Are they on DET’s permitted list?

2. Tax modelling: Test QFZP eligibility under multiple revenue mixes; ring-fence non-qualifying income if needed.

3. Contracting & invoicing: Update terms to reflect mainland execution, VAT treatment, governing law, and venue.

4. People & premises: Align MOHRE permits, insurance, and (if required) mainland workspace or client-site approvals.

5. 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.

Contact us today.