The short answer
Dubai Executive Council Decision No. 11 of 2025 allows free zone companies to conduct business on the Dubai mainland under a permit issued by the Department of Economy and Tourism — without forming a separate mainland entity. The permit costs AED 10,000 for a branch or AED 5,000 for a temporary activity. This is the most significant structural change to Dubai's free zone and mainland commercial framework in over a decade.
The problem Decision 11/2025 solves
For years, free zone companies in Dubai faced a fundamental commercial constraint. A business registered in DMCC, DIFC, JAFZA, or any of Dubai's 30+ free zones could benefit from 100% foreign ownership and — subject to qualifying conditions — a 0% corporate tax rate. But the moment that business needed to sell directly to a mainland UAE customer, it faced two unpleasant choices.
The first was forming a parallel mainland LLC — a separate legal entity with its own trade licence, registered address, bank account, audit obligation, and annual renewal costs typically adding AED 19,500 to AED 25,000 per year.
The second was routing all mainland transactions through a mainland distributor or agent, sacrificing margin and control in exchange for market access.
Decision 11/2025 creates a third option. A free zone company can now access the Dubai mainland market through a permit attached to its existing legal entity — at a fraction of the cost of a parallel mainland LLC, with a single consolidated audit, and without managing two separate corporate structures.
What Decision 11/2025 actually says
The permit structure
Free zone companies apply to the DET for either a branch permit (AED 10,000) for ongoing mainland activities, or a temporary activity permit (AED 5,000) for project-based or occasional work.
Single entity structure
The permit does not create a new legal entity. The free zone company remains the single legal person. The permit extends its operating rights into the mainland — it is not a second company.
Activity alignment requirement
The mainland activity permitted under the Decision must exactly mirror the licensed activity in the free zone. A commodity trading company cannot use a Decision 11 permit to conduct engineering consulting on the mainland.
Physical substance
The branch permit requires demonstrable physical or operational presence for mainland activities. Virtual office arrangements alone do not satisfy the substance requirement.
Financial record segregation
Revenues and expenses attributable to mainland activities must be maintained in separate accounting records. This has direct implications for corporate tax and QFZP status.
The two permit types — which one applies to you
The Branch Permit — AED 10,000
The right choice for free zone companies with regular, recurring, or ongoing mainland business activities. Examples: a DMCC commodity trading company that regularly supplies goods to mainland distributors; a DIC technology company providing ongoing IT managed services to mainland corporate clients; a JAFZA logistics company managing mainland last-mile delivery operations.
The branch permit is renewable annually, appears as a branch listing in the DET commercial register, and is verifiable by mainland clients and government entities.
The Temporary Activity Permit — AED 5,000
Designed for project-based, time-limited, or occasional mainland activities. Examples: a Dubai Design District agency that has won a single mainland government contract; a DMCC fintech company conducting a one-time product launch at a mainland venue; a free zone consultancy engaged for a defined-scope advisory project.
The temporary permit is issued for the duration of a specific project with a defined end date. It expires automatically when the activity concludes. It cannot be used to establish a permanent mainland commercial presence.
What Decision 11/2025 does not cover
Outside Dubai
Decision 11/2025 is a Dubai Executive Council regulation covering mainland Dubai only. Free zone companies wanting to conduct business in Abu Dhabi, Sharjah, or other emirates must follow those emirates' own frameworks.
Free zone licence restrictions
Some free zones impose their own restrictions on mainland activities — requiring a NOC or containing charter limitations. Decision 11/2025 does not supersede these free zone-level rules. The NOC from the parent free zone authority is required before the DET permit can be applied for.
QFZP compliance requirements
Free zone companies holding Qualifying Free Zone Person status must continue meeting all QFZP conditions. Mainland branch income under a Decision 11 permit is assessed separately and may not qualify as QFZP income, affecting the overall tax position.
Government tendering
Mainland government entities typically require suppliers to be registered on the central government procurement platform. A Decision 11 permit alone may not satisfy procurement registration requirements.
All economic activities
Regulated activities — financial services, healthcare, legal practice — may require additional approvals from the relevant regulatory authority beyond the DET permit.
The corporate tax implications — a critical consideration
For free zone companies holding Qualifying Free Zone Person status and benefiting from the 0% corporate tax rate, Decision 11/2025 introduces a compliance layer that must be managed carefully.
The key question for any QFZP using a Decision 11 permit is whether the mainland branch income constitutes qualifying or non-qualifying income. The answer depends on the nature of the activity, the counterparty, and the transaction structure.
The practical consequence of getting this wrong is severe: a single compliance failure — allowing non-qualifying income to exceed the de minimis threshold — results in immediate loss of the 0% rate for the entire tax period, with the company locked into the standard 9% rate until 2031.
Before using a Decision 11 permit to conduct mainland activities, every QFZP should obtain a documented tax position from a qualified UAE corporate tax advisor confirming the income characterisation of the proposed mainland transactions. This documentation is also the defence against FTA scrutiny in the event of an audit.
AMT Sphere advises on permit applications, NOC coordination with your free zone authority, activity alignment assessment, and the corporate tax position of mainland branch income. Book a free 15-minute call with our corporate structure team in Business Bay, Dubai.
Book a free call with our formation team →How to apply — step by step
- 01
Obtain a NOC from your free zone authority
Before approaching the DET, your free zone must confirm it does not object to you operating under a mainland permit. Processing time varies from 3 to 15 business days by free zone. Some free zones charge an administrative fee.
- 02
Confirm activity alignment
Verify that your intended mainland activity exactly mirrors your free zone licensed activity. If there is a mismatch, amend your free zone licence or restrict mainland operations to already-covered activities.
- 03
Prepare the DET application
Required: current valid free zone trade licence, NOC from your free zone authority, details of the intended mainland activity. For the branch permit, also include evidence of physical presence — a mainland lease, service agreement, or operational plan showing staff or assets based in the mainland.
- 04
Submit through the DET portal
The application is submitted through business.dubai.gov.ae or an authorised typing centre. Processing time is typically 5 to 10 business days for complete applications.
- 05
Update your accounting records
Upon permit issuance, immediately update your accounting systems to segregate mainland branch revenues and expenses into a separate cost centre or subsidiary ledger. This satisfies the Decision 11 record-keeping requirement and supports your corporate tax filing.
Decision 11 permit vs parallel mainland LLC
| Factor | Decision 11 Permit | Parallel Mainland LLC |
|---|---|---|
| Setup cost | AED 10,000 (branch) or AED 5,000 | AED 19,500–25,000 |
| Annual renewal | AED 10,000 | AED 15,000–20,000 |
| Legal entities | One — your free zone company | Two separate entities |
| Bank accounts | Single consolidated account | Separate mainland account required |
| Audit requirement | Single consolidated audit | Separate audit per entity |
| UAE-wide mainland access | Dubai only | All emirates |
| Government tendering | May need additional registration | Directly eligible |
| Speed to activate | 1–3 weeks | 4–8 weeks |
| Complexity | Low | High |
Frequently asked questions
Does Decision 11/2025 apply to all Dubai free zones?↓
Can I use a Decision 11 permit to hire mainland employees?↓
What happens to my permit if my free zone licence lapses?↓
How does mainland branch income affect my QFZP corporate tax status?↓
Is Decision 11/2025 the same as a dual licence?↓
Can I open a mainland bank account under the Decision 11 permit?↓
Find out if Decision 11/2025 is the right structure for your free zone business.
AMT Sphere advises on permit applications, free zone NOC coordination, activity alignment, and the corporate tax position of mainland branch income. Business Bay, Dubai.
Book a free structure review →Available Mon–Fri, 9am–6pm GST