阿联酋 dual licensing

Dual licensing is an arrangement through which a company registered in a 阿联酋 自由区 receives additional authorisation to conduct specified activities outside that 自由区.

The company retains its original 自由区 registration while obtaining a Mainland 执照, branch 执照 or activity-specific permit from the relevant Mainland authority. The legal structure and permitted scope depend on the programme being used.

Dual licensing does not necessarily mean that two separate companies are created. In many cases, the Mainland authorisation is connected to the existing 自由区 legal entity. A licensed branch generally does not have a legal personality independent of its parent 自由区 company.

The term "dual 执照" is often used broadly in the market, but several legally different arrangements may be involved:

It is therefore important to identify the exact authorisation being offered instead of relying only on the label "dual 执照."

Yes, an eligible 自由区 company may legally operate in the Mainland when it obtains the 执照, permit or other approval required by the competent Mainland authority.

A standard 自由区 执照 primarily authorises the company to operate within the scope of the issuing 自由区. It should not be assumed that the 执照 alone permits the company to establish Mainland premises, perform regulated work at Mainland locations, open a retail outlet or undertake every form of direct local trading.

The appropriate route may include:

The right solution depends heavily on the business model. A consultancy performing short-term projects may need a different structure from a retailer, construction contractor, medical provider or goods importer.

No. The 阿联酋 does not have one universal Mainland permit that automatically authorises a 自由区 company to operate in every emirate.

Economic licensing is administered through the competent 主管部门 of the respective emirates, alongside the relevant 自由区 authority and any federal or local sector regulator.

A permit issued by 迪拜's 经济与旅游局 concerns activities conducted outside 迪拜 free zones but within the Emirate of 迪拜. If the company intends to establish permanent operations in Abu Dhabi, Sharjah or another emirate, it may need authorisation from the competent authority in that jurisdiction.

This distinction is especially important for companies with clients across the 阿联酋. Serving a customer in another emirate does not always mean that the company has established a regulated operational presence there. However, opening premises, assigning staff permanently, operating a shop or facility, or performing an activity requiring local supervision can trigger additional licensing requirements.

迪拜 Executive Council Resolution No. 11 of 2025 created a formal framework for establishments registered 在迪拜 free zones that want to perform activities outside their free zones and within 迪拜.

The Resolution does not apply to financial establishments licensed to operate in the 迪拜 International Financial Centre. DIFC entities and regulated financial businesses are governed by separate rules and should obtain specialised advice before undertaking activities outside their licensed jurisdiction.

Under the Resolution, the 迪拜 经济与旅游局 may authorise an eligible 自由区 establishment through one of three routes:

Each route has a different purpose, validity period, cost and operational effect.

A 自由区 company may apply to establish a branch with a physical location in Mainland 迪拜.

The branch is legally connected to the 自由区 parent company. Under the 迪拜 Resolution, it does not have a separate legal personality and is not considered independent from its parent.

Eligibility generally requires:

Premises-related costs, tenancy registration, external approvals and ordinary licensing charges may apply depending on the activity and location.

迪拜's framework also permits DET to issue a branch 执照 that allows the 自由区 establishment to conduct approved Mainland activities while operating from its existing 自由区 location.

This may be attractive to businesses that require ongoing Mainland access but do not need a second physical office.

The official Resolution prescribes an annual fee of AED 10,000 for issuing or renewing this type of branch 执照. This 金额 should not be treated as the entire cost of the arrangement. The company may also incur 自由区 approval fees, 文件准备 costs, activity charges, external-approval costs and professional fees.

The application may require:

The licensed activities must remain within the scope approved by the 主管部门. The branch cannot use its Mainland authorisation to undertake unrelated activities.

An eligible 迪拜 自由区 company may apply for a temporary permit to undertake specified activities within Mainland 迪拜.

Under Executive Council Resolution No. 11 of 2025, the temporary permit may be valid for a period not exceeding six months. The official fee for issuing or renewing the permit is AED 5,000.

迪拜 subsequently launched the 自由区 Mainland Operating Permit framework in cooperation with the 迪拜 自由区 Council. Eligible companies holding a 迪拜 Unified 执照 can apply through the Invest 在迪拜 platform.

The actual activity list and applicant eligibility must be checked at the time of application. The inclusion of a general activity category does not guarantee that every activity within that category will qualify.

Businesses requiring permanent premises or continuous Mainland operations may find a branch 执照 more appropriate.

Abu Dhabi also offers an official Dual 执照 through the Abu Dhabi Department of Economic Development.

ADDED describes this 执照 as allowing establishments registered in Abu Dhabi free zones to conduct their activities and manage their businesses outside the 自由区.

The programme can help qualifying companies access the Abu Dhabi Mainland while retaining their 自由区 presence. However, the exact permitted activities, required approvals, premises position and supporting 文件 must be confirmed through ADDED and the applicable 自由区.

The availability of a Dual 执照 in Abu Dhabi does not mean that a 迪拜, Sharjah or other non-Abu Dhabi 自由区 company automatically qualifies for the same route. Eligibility is connected to the issuing authority's rules.

Which 自由区 Companies May Qualify?

A company should obtain confirmation from both the 自由区 authority and the Mainland licensing authority before making contractual or operational commitments.

Are All Business Activities Eligible?

No. Dual licensing does not automatically cover every 业务活动.

The competent Mainland authority determines which activities may be performed under a temporary permit, branch 执照 or other form of authorisation. Some activities are non-regulated and relatively straightforward, while others require approvals from specialist regulators.

Activities that may require additional review include:

The 业务活动 on the Mainland authorisation should align with the company's 自由区 执照 and 章程文件. If the proposed Mainland activity is materially different, the company may first need to amend its 自由区 执照.

Potentially, yes. 迪拜's 自由区 Mainland Operating Permit was introduced with domestic trading among its intended commercial uses. Nevertheless, trading goods raises additional issues beyond the business permit itself.

A company may need to consider:

A Mainland operating permit should not be treated as a substitute for customs clearance or product approval.

迪拜 Customs states that a 执照 holder involved in customs activities must obtain a Customs Business Code and submit the appropriate declaration for the relevant movement of goods.

It can, but only when the relevant retail activity and premises are specifically authorised.

Operating a physical shop, showroom, food outlet, clinic or customer-service centre can require more than general permission to work with Mainland clients. Premises may need to satisfy:

Where a permanent retail location is required, a Mainland branch with approved premises may be more suitable than a temporary activity permit.

迪拜's 自由区 Mainland Operating Permit was introduced partly to expand access to government tenders and domestic contracts. An eligible permit may therefore help a 自由区 company participate in procurement opportunities that require Mainland operating authority.

However, the permit does not guarantee tender eligibility or contract award. Each purchasing body may impose separate requirements relating to:

The company should review the tender 文件 before choosing a licensing route.

Under 迪拜 Executive Council Resolution No. 11 of 2025, an establishment authorised under the framework may engage its existing workforce registered through the 自由区 portal and continue benefiting from the applicable 自由区 employment privileges.

This is a useful feature of the 迪拜 framework because it may avoid the need to create an entirely separate workforce merely to undertake approved Mainland activities.

It does not remove the company's other responsibilities. The employer must continue to comply with applicable employment, immigration, health and safety, 保险, site-access and professional-qualification requirements.

Certain projects or regulated premises may require additional employee permits, professional cards or site approvals.

"Operating on the Mainland" is too broad for licensing purposes. The application should clarify whether the company will provide consultancy, trade goods, open premises, perform project work, participate in tenders or establish a permanent branch.

Determine where the activities will physically and commercially take place.

A 迪拜 permit concerns activities within 迪拜. Operations in another emirate may require authorisation from that emirate's competent authority.

Check whether the proposed Mainland activity is already included in the 自由区 执照 and 章程文件.

If the activities do not align, an amendment may be necessary before applying for Mainland authorisation.

Confirm whether the activity qualifies for:

Do not assume that a general category such as "consultancy" or "trading" includes every activity within that category.

Apply for the required approval or no-objection certificate from the 自由区 licensing authority.

The 自由区 may review the company's 执照 status, 合规 record, facilities, proposed activity and 章程文件.

If the activity is regulated, obtain the necessary approvals from the competent regulator.

The Mainland authority may not issue the final 执照 or permit until these approvals are available.

Choose between a temporary permit and a branch 执照 based on the operational model.

A temporary permit may suit limited or trial operations. A branch 执照 may be better for permanent activity, ongoing contracts or premises-based operations.

Compile the company, manager, shareholder and approval 文件. Ensure names, 执照 numbers, activities and ownership information are consistent across all records.

Eligible 迪拜 applicants may use the Invest 在迪拜 platform. Other applications may be submitted through the competent economic department or its service channels.

Pay the authority fees and any additional charges imposed by the 自由区, regulator or service provider.

Check the issued document carefully, including:

Create separate records for Mainland activities where required. Update invoicing, contracts, tax coding and internal approval processes before beginning operations.

How Much Does a Mainland Permit Cost?

AED 10,000 per year for issuing or renewing a branch 执照 operating from the 自由区

These figures relate to the specified DET authorisations. They may not represent the complete cost of becoming operational.

Additional expenses can include:

The fee for a conventional branch with physical Mainland premises depends on the applicable licensing and premises requirements.

CTA: Request a tailored cost assessment based on your 自由区, activities and intended Mainland operations.

How Long Does the Application Take?

The 时间表 depends on:

A straightforward application for an eligible non-regulated activity may be processed more efficiently than a branch requiring premises, regulatory approval or technical inspection. Companies should avoid committing to a project start date until the relevant authorisation has been issued.

Dual licensing can affect the 企业所得税 treatment of a 自由区 company.

A 自由区 entity is not automatically exempt from 企业所得税. A company seeking the zero-percent rate available to a Qualifying 自由区 Person must satisfy all applicable conditions, including requirements relating to qualifying income, adequate substance, 转让定价, audited financial statements and the de minimis limit for non-qualifying revenue.

Income attributable to a Mainland or domestic permanent establishment may not receive the same treatment as qualifying 自由区 income. The structure of the Mainland operation, personnel, premises, contracts and revenue-generating functions should therefore be reviewed before the company applies for a permit or branch 执照.

迪拜's 2025 Resolution expressly requires separate financial records for activities conducted outside the 自由区 and within 迪拜. This distinction supports regulatory and tax transparency, but accounting separation alone does not determine whether income qualifies for a particular 企业所得税 rate.

The company should assess:

A licensing decision should not be made without considering its tax consequences.

自由区 companies are subject to the 阿联酋 增值税 legislation. Merely operating in a 自由区 does not create a general 增值税 exemption.

A business must generally register for 增值税 when its taxable supplies and imports exceed the mandatory threshold of AED 375,000. Voluntary registration may be available when taxable supplies, imports or qualifying expenses exceed AED 187,500.

增值税 treatment depends on:

The movement of goods from a 增值税 Designated Zone into Mainland 阿联酋 is generally treated as an import. Import 增值税 may therefore become payable by the importer, followed by the 增值税 treatment applicable to any subsequent Mainland sale.

A 迪拜 自由区 establishment authorised to operate in Mainland 迪拜 must maintain separate financial records for the activities it conducts outside the 自由区.

The company should establish accounting controls that identify:

Contracts and invoices should identify the correct entity and authorisation. Using inconsistent trade names, 执照 details or tax-registration information can create problems during audits, customer onboarding and payment processing.

A Mainland permit or branch 执照 may strengthen the commercial 文件准备 available to a 自由区 company, but it does not guarantee bank-account approval.

The bank may request:

If a separate branch account or merchant facility is required, the bank will determine whether it can be opened under the existing legal entity and customer profile.

Does the Mainland Branch Have Separate Legal Personality?

Under 迪拜's 2025 Resolution, a branch licensed within Mainland 迪拜 or a branch operating from the 自由区 does not have a separate legal personality and is not considered independent of its parent company.

The 自由区 company remains responsible for the branch's contracts, liabilities and regulatory obligations. This differs from forming a separate Mainland subsidiary, which has its own legal personality.

The absence of separate legal personality can simplify ownership but also means that liabilities arising from branch operations may affect the parent company directly.

A separate Mainland company may be preferable when:

The least expensive structure at the beginning is not always the most efficient long-term structure.

A goods-trading 自由区 company may sometimes access the local market through a licensed Mainland distributor rather than obtaining its own Mainland authorisation.

A distributor arrangement may be suitable where:

Direct Mainland authorisation may provide greater control over customers, 费用 and operations. However, it also creates additional licensing, customs, tax and 合规 responsibilities.

The commercial agreement should clearly define responsibility for importation, customs duties, 增值税, product registration, returns, warranties and consumer complaints.

A dual-licensed company must maintain both sides of its regulatory structure.

Typical continuing obligations include:

A temporary permit should not be allowed to expire while the company continues Mainland operations. Operating outside the authorised period or activity scope may expose the business to penalties and contractual risk.

A 自由区 执照 alone does not automatically authorise every Mainland activity. The company should confirm the legal route before beginning local operations.

A temporary permit may be insufficient for a permanent shop or facility. Conversely, a full Mainland branch may be unnecessarily costly for a limited project.

The activity on the Mainland application must correspond with the company's existing 自由区 activities and the authority's eligible list.

A general permit does not replace approvals required for 医疗保健, engineering, 教育, food, 金融服务 or another regulated field.

迪拜's framework requires separate records for Mainland activities. Inadequate accounting can create licensing and 企业所得税 complications.

An authorisation to operate within 迪拜 does not automatically grant operating rights in every other emirate.

A business permit does not replace customs declarations, product registration, conformity assessment or import approval.

Temporary permits and branch licences have defined validity periods. Renewal planning should begin before expiry.

A 迪拜 自由区 technology consultancy wants its employees to work periodically at customer offices. If its activity is eligible, a temporary Mainland operating permit may provide an efficient route without requiring a second permanent office.

If the company expects continuous Mainland work and recurring tenders, a branch 执照 operating from the 自由区 may offer greater continuity than repeated temporary permits.

A 自由区 company planning a permanent retail outlet is likely to require a branch or another Mainland structure with approved premises. A temporary professional-services permit may not meet the operational requirements.

The company must assess its Mainland trading authority, customs registration, importer-of-record arrangement, product approvals, 增值税 treatment and logistics. A permit alone does not complete the import and distribution framework.

A 迪拜 自由区 company that wants permanent operations in Abu Dhabi must check the licensing requirements of Abu Dhabi's competent authority. Its 迪拜 permit cannot simply be extended across the 阿联酋.

Before applying, confirm that:

KPM Global Services can help an existing or proposed 自由区 company evaluate the most appropriate route into the Mainland market.

Every application remains subject to the decisions of the relevant 自由区, economic department and sector regulator. KPM Global Services does not guarantee government, banking or regulatory approval.

No. Eligibility depends on the emirate, 自由区, legal form, 业务活动 and applicable Mainland-licensing programme. Approval from the 自由区 authority and the Mainland authority may be required.

Yes, an eligible company may apply for a Mainland branch 执照 or temporary permit under 迪拜's applicable framework. It cannot assume that its original 自由区 执照 alone is sufficient.

3. What is 迪拜's 自由区 Mainland Operating Permit?

It is a Mainland-access framework that allows eligible 迪拜 自由区 companies holding a 迪拜 Unified 执照 to apply to perform approved activities in Mainland 迪拜.

Executive Council Resolution No. 11 of 2025 allows DET to issue a temporary permit valid for no more than six months. It may be renewable subject to the prevailing conditions.

The Resolution prescribes AED 5,000 for issuing or renewing the temporary permit. 自由区 approvals, activity amendments, regulatory approvals and professional services may cost extra.

The prescribed DET fee is AED 10,000 per year for issuing or renewing this branch 执照. Additional government, 自由区 and 合规 costs may apply.

Not always. A branch operating from the 自由区 may use the existing 自由区 location where permitted. A conventional Mainland branch or premises-based activity may require a Mainland office, shop or facility.

The 迪拜 Resolution requires approval from the relevant 自由区 licensing authority. The authority may issue an NOC or another form of approval according to its procedures.

迪拜's 2025 Resolution permits an authorised establishment to engage its existing workforce registered through the 自由区 portal. Other employment, professional and site-specific rules still apply.

Potentially, if the trading activity is eligible and included in the permit or 执照. The company may additionally need customs registration, product approvals, import 文件准备 and 增值税 合规.

No. A 迪拜 authorisation applies within 迪拜. Activities conducted in another emirate may require approval from that emirate's competent authority.

Yes. ADDED officially offers a Dual 执照 for eligible establishments registered in Abu Dhabi free zones that want to conduct approved activities outside their free zones.

A suitable Mainland authorisation may allow participation in eligible tenders, but each government entity maintains its own supplier-registration and procurement requirements. Contract awards are not guaranteed.

It may. Income attributable to Mainland operations may not qualify for the zero-percent treatment available to a Qualifying 自由区 Person. The effect depends on the structure, activity, income and 合规 with 企业所得税 conditions.

迪拜's Resolution requires separate financial records for activities conducted outside the 自由区 and within 迪拜. The company should be able to distinguish Mainland revenue, costs, assets and tax treatment.

A 迪拜 branch licensed under the 2025 Resolution does not have a legal personality independent of its 自由区 parent. A separately incorporated Mainland subsidiary would be a distinct entity.

Regulated activities may be excluded from a simplified permit or may require approval from the relevant sector regulator. Eligibility must be checked for the exact activity.

Only if the chosen route, approved activity and premises satisfy all applicable licensing conditions. A permanent retail outlet may require a Mainland branch, approved tenancy and additional municipal or sector approvals.

It depends on the business model. A permit offers more direct operational control, while a distributor may handle importation, logistics and local sales. Costs, responsibilities and customer ownership should be compared carefully.

The Mainland authorisation normally depends on the underlying 自由区 执照 remaining valid. Failure to renew the 自由区 执照 can affect the company's continued eligibility to conduct Mainland activities.