Pre-heading: DUBAI FREE ZONE AND MAINLAND BUSINESS EXPANSION

Confirm the legal entity, issuing authority and exact activities.

Identify customers, locations, contracts, goods, employees and premises.

Identify every external approval required.

Confirm whether the activity and Free Zone qualify for the operating-permit route.

Evaluate a permit, branch, distributor and separate mainland LLC.

Determine whether the operation creates non-qualifying income or a Domestic Permanent Establishment.

Confirm invoicing, importer responsibilities and product treatment.

Secure any no-objection certificate, resolution or supporting document required.

Submit the permit or branch application with the necessary supporting records.

Obtain an office, shop or warehouse suitable for the activity.

Confirm how existing staff can perform mainland duties.

Create ledgers, cost centres and records for mainland activity.

Update the company's operating profile where necessary.

Do not exceed the permit, branch or external approval.

Review the structure before each licence, permit and tax-reporting deadline.

The official operating permit was launched at AED 5,000 for six months, renewable for the same period and fee. This amount should be reconfirmed and should not be treated as the entire operational cost.

The licence is issued under a particular Free Zone framework. Mainland operations may require DET approval.

Permits, branches and direct structures may now be available.

It applies only to eligible activities and approved operations.

Mainland operations can create taxable income at 9% and affect Qualifying Free Zone Person analysis.

Separate financial records are required for authorised mainland operations.

Not every Free Zone is a Designated Zone, and Designated Zone treatment is limited.

Yes, a Free Zone company can conduct eligible business in the Dubai mainland—but it must use a legally permitted route.

A Free Zone licence does not automatically authorise unrestricted operations everywhere in Dubai. Depending on the activity, the company may need a mainland operating permit, a branch licence from the Dubai Department of Economy and Tourism, a mainland distributor or importer, a dual-licensing arrangement, or an independently incorporated mainland company.

Dubai materially expanded the available options through Executive Council Resolution No. 11 of 2025. Under this framework, a company licensed by a Dubai Free Zone authority may operate outside its Free Zone and within the Emirate of Dubai after obtaining the required licence or permit from the Dubai Department of Economy and Tourism.

Dubai subsequently introduced the Free Zone Mainland Operating Permit for eligible non-regulated activities. This creates a more direct path for certain Free Zone companies to undertake approved mainland operations without immediately establishing a separate mainland company.

KPM Global Services LLC can review a Free Zone company's licence, business model, customers and tax position before recommending the appropriate Dubai mainland operating route.

A Dubai Free Zone company may conduct business in the Dubai mainland through one or more of the following routes:

Online or cross-border transactions that do not require an additional physical mainland presence, subject to the applicable rules

The company should not assume that issuing an invoice to a mainland customer is the only test.

Executive Council Resolution No. 11 of 2025 established a clearer legal framework for Free Zone establishments seeking to conduct activities outside their zones and within Dubai.

The Resolution applies to Free Zone establishments operating outside their designated zones, with an exception for financial institutions licensed in the Dubai International Financial Centre, which remain subject to their specialised framework.

Under the Resolution, a Dubai Free Zone establishment may operate outside its Free Zone after obtaining the necessary licence or permit from DET. Dubai Legislation Portal

Branch licences issued under the framework are generally valid for one year and may be renewed, subject to the applicable conditions.

The Resolution does not mean every Free Zone company can automatically perform every activity in mainland Dubai. DET and the relevant Free Zone authority determine activity eligibility, licensing conditions and coordination requirements.

Dubai introduced the Free Zone Mainland Operating Permit as an implementation route supporting eligible Free Zone businesses that want to operate in mainland Dubai.

According to the official Dubai announcement, the initial phase covers certain non-regulated activities, including areas such as:

Eligibility depends on the approved activity and participating licensing framework. A company should not rely only on a broad activity category. Its exact licensed activity must be checked.

Designed to allow eligible Free Zone companies to conduct approved mainland operations

Capable of supporting use of the company's existing workforce for authorised mainland activities

The current fee and conditions should be reconfirmed before applying. Government of Dubai Media Office

Does Every Dubai Free Zone Company Qualify?

A company established in another emirate's Free Zone should not assume that Dubai's local permit framework applies to it in the same manner.