What the resolution actually does
Dubai Executive Council Resolution 11 of 2025 — issued February 2025, effective 1 March 2025 — permits free-zone companies licensed by any Dubai free-zone authority to expand into mainland Dubai through a permit issued by DET. It (i) creates a dual-licensing permit directly with DET, (ii) lets the mainland activity be conducted under the free-zone company's legal personality without a separate mainland entity, (iii) sets a single-permit-per-activity approach drawn from DET's unified activity catalogue.
Who benefits and who does not
Strong fit: Consultancy and professional services firms in DMCC, DIFC (non-financial), Dubai Media City, IFZA already serving mainland clients through workarounds. SaaS providers. Marketing/PR/creative agencies.
Weak fit or no benefit: Companies in Designated Zones for VAT (adding mainland may compromise treatment). QFZP-relying companies (mainland revenue is automatically Non-Qualifying; breaching 5%/AED 5M de minimis loses QFZP entirely). Companies pursuing UAE-national workforce contracts. DIFC financial services (DFSA activities can't be conducted on mainland under the permit).
Mechanics: how the permit is issued
Five steps. Activity mapping to DET's unified catalogue. NOC from the free zone (AED 1,000-2,500, 3-7 days). DET application via Invest in Dubai portal with NOC, MOA, board resolution, lease, UBO declaration. Permit issuance (one-year, renewable). FTA single-TRN registration; MOHRE registration for mainland-based employees.
Cost stack
Realistic first-year cost (excluding office rent and visa quotas):
DET dual-licensing permit fee: AED 12,000 - 18,000.
Free zone NOC: AED 1,000 - 2,500.
Activity-specific approvals (DHA, RTA, etc.): variable.
Mainland address (Flexi-Desk or shared office): AED 15,000 - 35,000/year.
Total annual added cost: AED 30,000 - 60,000.
Branch vs full conversion: when each makes sense
Option A — Dual-licensing permit: Best for free-zone companies adding mainland revenue at the margin (under 30% of total).
Option B — Mainland branch: Best where mainland revenue is meaningful (30%+) or where LSA arrangements are required.
Option C — Full conversion to mainland LLC: Best where free-zone benefits (QFZP, specialised licensing) are no longer load-bearing. The Cabinet Resolution 55/2021 Positive List has reduced the historical case for the free-zone wrapper.
VAT, CT, and 12-month observations
FTA June 2025 guidance confirmed single-TRN treatment. Supply rules still depend on location, not licence. For QFZP: mainland revenue is Non-Qualifying — run a forward-looking model before applying. First 12 months show permits being granted in 18-28 days for clean files; DET rejects where proposed activity is materially broader than the parent licence; QFZP-loss is the single most common post-implementation problem.