Dubai Industrial City in 2026: Regulation, Free Zone Status, VAT and Corporate Tax

Dubai Industrial City is a TECOM Group industrial district in Dubai that sits administratively within the jurisdiction of the Dubai Development Authority (DDA), which states on its own site that it is responsible for company registration and licensing across the group’s districts. No published Dubai instrument names the district as a free zone, and for VAT Dubai Industrial City is not on the Designated Zone list — which is what drives the economics of locating there.

Three things to establish before any budget is built.

One: Dubai Industrial City’s free zone status is not expressly confirmed by any published instrument.Dubai Law No. 8 of 2023 attached to Law 15/2014 a schedule of twenty-four land plots constituting the free zone, but the district is not named in it and the demarcating plans are not attached to the published text. The practical consequence: the district’s status for tax purposes is confirmed by a written answer from the DDA, exactly as the Federal Tax Authority’s guide directs, rather than by pointing at a public instrument.

Two: Dubai Industrial City is not a VAT Designated Zone. The Federal Tax Authority’s published list carries seven live Dubai entries, and Dubai Industrial City is not among them. The practical consequence: supplies within the district and into mainland Dubai are standard-rated at 5 per cent, and moving goods from Dubai Industrial City to JAFZA is not an export.

Three: manufacturing in Dubai Industrial City can be a Qualifying Activity for corporate tax; distribution cannot. Ministerial Decision No. 229 of 2025 lists “Manufacturing of goods or materials” and “Processing of goods or materials” with no Designated Zone condition attached, but lists distribution only “in or from a Designated Zone”. For a Dubai Industrial City tenant that means distribution revenue from sales to customers outside the free zones cannot be Qualifying Income and eats into the de minimis allowance. The one exception is limb (a) of article 3(1) of Cabinet Decision No. 100 of 2023: sales to Free Zone Persons who are the Beneficial Recipients of the goods qualify with no Designated Zone condition at all.

The Legal Framework: Who Regulates Dubai Industrial City, and Under What

Dubai Industrial City is regulated on three levels: the emirate level, through the legislation governing the Dubai Development Authority; the federal level, through UAE tax and industrial legislation; and the contractual level, through TECOM Group’s own rules as landlord. The three must not be run together: the DDA issues the licence but does not determine the district’s VAT status, and the federal legislator determines the tax but not the district’s boundaries.

The emirate’s constitutive chain runs to four instruments, the last amendment to it dated 2023. Separately from that chain, Executive Council Resolution No. 11 of 2025 has governed free zone companies operating outside their zones since 2025; it does not amend the chain, but it is the instrument that applies to a zone tenant selling on the mainland.

Instrument	Date of issue	Entry into force	What it did
Law No. (1) of 2000 on the Dubai Technology, Electronic Commerce and Media Free Zone	31 January 2000	on publication (art. 30)	Established the first version of the regime; repealed
Law No. (15) of 2014Concerning Creative Clusters in the Emirate of Dubai	27 October 2014	“will come into force on the day on which it is published” (art. 32)	Established the Dubai Creative Clusters Authority; art. 31(a): “This Law supersedes the above­-me­ntioned Law No. (1) of 2000”
Decree No. (30) of 2017	11 July 2017	on the day of issue	Extended the clusters’ urban planning and construction legislation to land owned by Dubai Holding, Meraas LLC, Al Shemal Holding LLC and their affiliates
Law No. (10) of 2018 Changing Names Related to the Dubai Creative Clusters Authority	19 September 2018	“comes into force on the day on which it is issued”	Renamed the DCCA the Dubai Development Authority; replaced “Creative Clusters” with “Clusters” and “Creative Products” with “Products”
Law No. (8) of 2023 Amending Law No. (15) of 2014 Concerning the Dubai Development Authority	6 February 2023	“comes into force on the day on which it is issued”	Substituted a new article 3 into Law 15/2014 and attached a schedule of the land plots constituting the free zone

What Decree No. (30) of 2017 actually did, and what it did not do. Article 1(a) extends the “Dubai Creative Clusters Urban Planning and Construction Legislation” to land owned by Dubai Holding and its affiliates — that is planning and building-control jurisdiction, not tax or customs jurisdiction. Author’s assessment: building control and free zone status are separate subjects and are worth separating from the outset, because the answers on both VAT and corporate tax depend on the distinction.

The federal layer is what determines the tax and the industrial licence.

Instrument	Date of issue	Entry into force
Federal Decree-Law No. 8 of 2017 on VAT, as amended by Federal Decree-Laws Nos. 18/2022, 16/2024 and No. 16/2025	No. 16/2025 — 1 October 2025	1 January 2026
Cabinet Decision No. 52 of 2017 — the VAT Executive Regulation, as amended through to Cabinet Decision No. 100 of 2025	No. 100/2025 — 12 August 2025	29 September 2025
Cabinet Decision No. 59 of 2017 on Designated Zones, as amended by Nos. 35/2018, 43/2019, 34/2021, 63/2021 and 81/2021	—	last amendment effective 12 September 2021
Federal Decree-Law No. 47 of 2022 on Corporate Tax, as amended by Nos. 60/2023, 40/2024 and No. 28/2025	No. 28/2025 — 1 October 2025	15 October 2025
Federal Decree-Law No. (25) of 2022 on the Regulation and Development of Industry	26 September 2022	2 January 2023

Separately, the instruments that no longer have effect and must not be cited. On free zone corporate tax: Cabinet Decision No. 55 of 2023 was repealed by article 10 of Cabinet Decision No. 100 of 2023; Ministerial Decision No. 139 of 2023 was repealed by Ministerial Decision No. 265 of 2023; and Ministerial Decision No. 265 of 2023 was itself repealed by article 6 of Ministerial Decision No. 229 of 2025. What applies in 2026 is Cabinet Decision No. 100 of 2023 together with Ministerial Decision No. 229 of 2025.

> Author’s assessment: on this point even the regulator’s own guidance lags the law. The current edition of the Federal Tax Authority’s Corporate Tax Guide | Free Zone Persons | CTGFZP1 is dated May 2024 and cites the now-repealed Ministerial Decision No. 265 of 2023. The practical consequence: where the guide and the 2025 Ministerial Decision diverge, the Decision governs, not the guide.

The District Profile: History, Clusters and Scale

Dubai Industrial City was unveiled in November 2004 and sits in the industrial segment of the TECOM Group portfolio, whose shares have traded on the Dubai Financial Market since 5 July 2022. As at November 2024 the district hosts more than 1,100 local, regional and international businesses.

The district’s key dates.

Event	Date	Source
The district is unveiled as Dubai Industrial City	November 2004	TECOM Group, 21 November 2024
The district is named within TECOM Group’s Ma­nufactu­ring Cluster in the listing announcement	9 June 2022	Government of Dubai
TECOM Group shares begin trading on the Dubai Financial Market	5 July 2022	TECOM Group
An expansion phase is announced	28 May 2024	Dubai Industrial City
The district’s twentieth anniversary; “exceed 1,100 local, regional, and international businesses”	November 2024	TECOM Group
Land acquired to expand the district	28 August 2025	TECOM Group

The published measures of scale.

Metric	Figure	Source
Food and beverage cluster	23.5 million sq ft	Government of Dubai, 19 February 2024
Expansion phase announced 28 May 2024	13.9 million sq ft	Dubai Industrial City
Land acquisition to expand the district, 28 August 2025	138 plots, 33 million sq ft, an AED 1.6 billion investment	TECOM Group
TECOM Land Leasing segment gross leasable area	183 million sq ft, occupancy 96.6%	TECOM Integrated Report 2025
TECOM Industrial Leasing segment gross leasable area	11.9 million sq ft, occupancy 97.9%	TECOM Integrated Report 2025
TECOM Group total land portfolio	over 209 million sq ft	TECOM Integrated Report 2025
Power supply	up to 4 megawatts per plot against 800 MW of total available capacity	Dubai Industrial City
Internal road network	105 kilometres plus a 10-kilometre spine road	Dubai Industrial City, About Us

How to read these figures. TECOM Group discloses the Integrated Report 2025 metrics — gross leasable area, occupancy, average rate — by group segment rather than by individual district. The 183 million sq ft Land Leasing segment covers more than Dubai Industrial City, so it serves as an upper bound for the district rather than a measure of it. The practical consequence: the parameters of a specific plot — its area, term and rate — are worth obtaining as a commercial proposal from TECOM Group rather than inferred from group reporting.

The industrial specialisation is organised into six clusters: base metals, machinery, minerals, food and beverage, transport and chemicals. This is the set TECOM Group names when describing the district, and it defines the kinds of production the site was designed around.

Is It a Free Zone? The Question the Published Instruments Do Not Answer

Dubai Industrial City sits administratively within the jurisdiction of the Dubai Development Authority, and the DDA states expressly that it is responsible for company registration and licensing across TECOM Group’s districts. But no published Dubai instrument names Dubai Industrial City as a free zone, and the DDA’s own binding decision on licence categories does not extend to it.

What the regulator says. On its TECOM Group page the DDA lists twelve districts — Dubai Internet City, Dubai Outsource City, Dubai Industrial City, Dubai Media City, Dubai Studio City, Dubai Production City, Dubai Knowledge Park, Dubai International Academic City, Dubai Science Park, Dubai Design District, in5 and DQuarters — and states: “The Group’s business districts are located and operated under the jurisdiction of Dubai Development Authority (DDA), which is in charge of company registration and licensing”.

What the law says. Article 3 of Law No. 15 of 2014, as substituted by Law No. 8 of 2023, reads:

“This Law applies to: 1. the DDA…; 2. the Creative Clusters, and the land plots, whose boundaries and areas are demarcated on the plans attached to this Law and which constitute a free zone governed by the legislation applicable to the DDA, including the above-mentioned Decree No. (30) of 2017; and 3. any other zone or land plot that becomes subject to supervision by the DDA pursuant to a resolution issued by the Ruler, upon the recommendation of the Chairman.”

The schedule attached to Law No. 8 of 2023 contains twenty-four entries. Among them are plot No. 241 in Seih Shuaib 2, plots No. 63 and No. 41 in Seih Shuaib 3, and plot No. 59 in Seih Shuaib 4. Seih Shuaib is the locality in which Dubai Industrial City sits.

What the schedule actually lists, and what follows from it. The schedule names individual numbered plots, not whole localities. Plot No. 241 in Seih Shuaib 2 is one land parcel, not the whole of Dubai Industrial City with its 1,100-plus customers. The district is not named in Law No. 8 of 2023 or in Law No. 15 of 2014, and the plans demarcating the boundaries are not attached to the published text. Whether Dubai Industrial City’s customer plots fall inside the free zone perimeter cannot be established from published sources.

Four independent indicators point to Dubai Industrial City being regulated differently from the creative clusters.

Indicator	What was established
The DDA’s licence­-cate­gories decision	Its full title is “Decision No. 1 of 2021 Concerning Licence Categories for Dubai Internet City, Dubai Media City, Dubai Knowledge Park, Dubai International Academic City, Dubai Outsource City, Dubai Production City, Dubai Studio City, Dubai Science Park, Dubai Design District and Emirates Towers”. Ten named districts, and Dubai Industrial City is not one of them
DDA circulars	In the DDA’s public register of circulars and announcements for 2007–2026 Dubai Industrial City is named in no circular title, and no circular extends Decision No. 1 of 2021 to further districts
Dubai free zone enu­meratio­ns	Dubai Industrial City is absent from the standard lists of the emirate’s free zones, while every other TECOM district appears on them
The Invest in Dubai portal	Its page on Dubai’s industrial parks sits in the mainland companies section, structurally separate from the free zone section

The practical consequence for minimum capital. The AED 10,000 minimum paid-up capital for an FZ-LLC comes from article 15 of Decision No. 1 of 2021: “Subject to certain minimum paid up capital amounts set out below for specific segments and activities, for all other activities and for the purposes of Regulation 25.1 of the PCR, the minimum paid up capital of an FZ-LLC shall be AED 10,000”. AED 10,000 is a residual floor: the same article sets higher minima for named segments in Dubai Outsource City, Dubai Production City, Dubai Studio City, Dubai International Academic City and Dubai Design District, reaching AED 1,000,000 for broadcasting. By its own title the decision applies to ten named districts, among which Dubai Industrial City does not appear, so whether the figure applies to the district is a question for the DDA. The Private Companies Regulations 2016 themselves name no figure at all in Regulation 25.1: “The minimum issued fully paid up share capital of a company shall be such amount as the Registrar specifies from time to time.”

How the Federal Tax Authority itself frames the question. Its Free Zone Persons guide hands the question straight back to the zone authority: “All taxpayers should check with their respective Free Zone Authority to confirm if they operate in a Free Zone or Designated Zone for Corporate Tax purposes.” The Cabinet decision listing Free Zones for corporate tax purposes, to which both the guide and the FTA’s own bulletin refer, is published on neither tax.gov.ae nor mof.gov.ae.

> The honest formulation to work from. Dubai Industrial City is a TECOM Group district administered by the DDA; its land falls under the clusters’ planning legislation by Decree No. 30 of 2017; and the Seih Shuaib locality appears in the free zone plot schedule of Law No. 8 of 2023. But no published Dubai instrument names Dubai Industrial City as a free zone, and the DDA’s binding licence-categories decision does not extend to it. Author’s assessment: the practical conclusion for an investor is not to take the status on trust but to obtain written confirmation from the DDA, before filing, that the company is being registered in a Free Zone for corporate tax purposes. That is exactly what the FTA guide directs. The regime itself is analysed in The Qualifying Free Zone Person Regime in 2026.

The Six Sector Clusters and What the District Physically Offers

Dubai Industrial City is organised around six sector clusters: base metals, machinery, minerals, food and beverage, transport and chemicals. That is the official list, confirmed by three independent official sources.

The six clusters, in the official wording: “base metals; machinery; minerals; food and beverage; transport; and chemicals”. The same formulation appears in TECOM Group’s press release of 21 November 2024, in the Government of Dubai’s release of 19 February 2024, and in Dubai Industrial City’s own release of 28 May 2024.

Two of the six clusters map directly onto the emirate’s industrial strategy. Dubai Industrial Strategy 2030 names six priority sub-sectors: “Aerospace, Maritime, Aluminum and Fabricated Metals, Pharmaceuticals and Medical Equipment, Food and Beverages and Machinery and Equipment”. Food and beverage and machinery appear on both lists, and that overlap is the only documented link between the district’s sector structure and the emirate’s strategy.

What the district leases.

Product	Officially published parameters
Industrial land plots	Plot sizes and lease terms are not published
Pre-built warehouses	From 5,000 to 11,000 sq ft; a 6 × 6 metre sliding main door; units can be combined; office space and a retail showroom included; on-site parking and loading area; 24/7 security; fire protection systems. Permitted use: “Light manu­factu­ring, logistics and storage: cold, chemical and general”
Workers’ acco­mmoda­tion	More than 56,000 beds following the addition of a 14,000-bed village; more than AED 410 million invested across the two projects (figures as at 25 November 2020)
Showrooms, open yards, commercial and retail units	Parameters not published

The warehouse size range appears on the district’s page in two forms. The body text gives “5,000 to 10,000 sq. ft.”; the specification list on the same page gives “5000 to 11000 sq ft”. Both are reported here, and the exact dimensions of a given unit are confirmed by a commercial proposal.

Infrastructure and logistics — only what is officially stated.

•          Power supply: up to 4 megawatts per plot.

•          Internal road network: “105KM of road network with 10KM spine road (four lanes dual carriageway) linking the city from north to south”, per the current About Us page.

•          Available power: “A total of 800 megawatts is readily available”, at 4 MW per plot.

•          An Etihad Rail freight terminal is located within Dubai Industrial City — confirmed both by TECOM Group’s Integrated Report 2025 and by the district’s own industrial land page.

•          Proximity to Jebel Ali Port and Al Maktoum International Airport is stated only qualitatively: “strategically close to global trade routes”.

Neither Dubai Industrial City nor TECOM Group publishes a numeric distance to Jebel Ali Port or to Al Maktoum International Airport. Every specific “X kilometres” or “Y minutes” figure in circulation traces to property portals and company-formation websites. This analysis does not reproduce them. For comparison, JAFZA states on its own site that it is 24 km from Al Maktoum International and 40 km from Dubai International — but those are JAFZA’s distances, not Dubai Industrial City’s.

The presence of a dedicated customs post inside Dubai Industrial City could not be confirmed. Dubai Industrial City does not appear in Dubai Customs’ list of customs centres; TECOM appears there only inside the combined entry “Jebel Ali & TECOM Customs Center”, under the Jebel Ali division, and not as a centre in its own right. The practical consequence: the customs clearance route for a given plot is confirmed by an enquiry to Dubai Customs before a lease is signed.

Entity Forms, Licences and What It Costs

The Dubai Development Authority offers three forms of presence: an FZ-LLC, a branch of a foreign or local company, and a freelancer licence. There is no “sole establishment” form. Dubai Industrial City agrees its lease terms individually, so the only publicly verifiable charges are the DDA fees.

Form	The DDA’s definition
FZ-LLC	A free zone company in three registration variants: with a natural person, with a corporate person, or with both. The suffix “FZ-LLC” is mandatory in the name under Regulation 12.3.1 of the Private Companies Regulations
Branch of a foreign or local company	“a place of business that forms a legally dependent part of the parent company” — branch registration is provided for by section 9 of the Private Companies Regulations
Freelancer (Sole Professional Licence)	“for independent pro­fessio­nals, to conduct their profession by their birth name”

The DDA corporate rulebook.

Instrument	Status
Dubai Creative Clusters Private Companies Regulations 2016	In force. Regulation 3: they come into force “on the day they are published on the Authority’s website”; the instrument itself states no calendar date
Decision No. (2) of 2017 — fines and sanctions for PCR contra­ve­ntions	In force
Decision No. (3) of 2017 — amending PCR fees	In force
Decision No. (1) of 2021 — licence categories	In force, but applies to ten named districts, which do not include Dubai Industrial City
DTMFZ Licensing Regulations 2003	Listed as current in the DDA’s legal database
Decision No. (1) of 2014 and the 2018 Licensing Categories Decision	Repealed, moved to the DDA archive

No replacement rulebook was issued between 2024 and 2026. The Private Companies Regulations 2016 and Decision No. 1 of 2021 remain the operative instruments as at August 2026. The most recent DDA registration and licensing circular is Circular 670 of 3 June 2026 on the ultimate beneficial owner declaration process.

The official fees the DDA does publish.

Item	Amount
Re­gistra­tion fee	AED 3,500
Licence fee	“Calculated based on selected activity(s)” — there is no flat rate
Knowledge Dirham	AED 10 per transaction
Innovation Dirham	AED 10 per transaction

These fees are published by the DDA for the FZ-LLC route in the creative clusters, and carrying them across to Dubai Industrial City as “the district’s prices” is not sound. Given that the binding licence-categories decision does not extend to Dubai Industrial City, the applicability of this schedule to the district is not established. The practical consequence: a licence budget should be obtained from the DDA in writing for the specific activity and the specific district, not assembled from the published schedule.

Commercial terms — rent, lease length, visa allocation — are negotiated deal by deal: the district’s offering pages end in a contact form rather than a tariff. That is a landlord model rather than a packaged product, and the price turns on plot size, term, industry and the scale of the tenant’s commitment. The practical consequence: comparing the district with zones that publish package pricing is only meaningful against specific commercial proposals, which is why this analysis carries only the DDA fees that are officially published.

The only lease-duration datapoint in the group’s reporting is the weighted average lease term of TECOM Group’s Land Leasing segment, at 30.7 years in the Integrated Report 2025. That is a group segment metric, not a term offered in any particular Dubai Industrial City lease.

Whether Dubai Industrial City issues an industrial licence distinct from the general DDA licence could not be confirmed. The district’s website has no business-setup section, no licensing section and no relevant FAQ; its only legal page is the Terms and Conditions. Dubai Industrial City presents itself as a landlord and infrastructure operator, not as a licensing registry. A structurally comparable case, where operator and regulator are likewise separated, is analysed in Dubai Silicon Oasis and DIEZ in 2026.

VAT: Dubai Industrial City Is Not a Designated Zone

Dubai Industrial City does not appear on the list of VAT Designated Zones and never has. For a taxpayer that means the district is treated as ordinary UAE territory, with no “outside the State” treatment for movements of goods.

The Designated Zone list sits in Cabinet Decision No. 59 of 2017 and has been amended five times.

Instrument	Applies from
Cabinet Decision No. 59 of 2017 — the parent act	1 January 2018
Cabinet Decision No. 35 of 2018	18 June 2018
Cabinet Decision No. 43 of 2019	4 July 2019
Cabinet Decision No. 34 of 2021	4 April 2021
Cabinet Decision No. 63 of 2021	1 July 2021
Cabinet Decision No. 81 of 2021 — the most recent amendment	12 September 2021

The Dubai entries on the Federal Tax Authority’s published list, in order.

No.	Zone as listed	In force from	Removed from
1	Jebel Ali Free Zone (No­rth-Sou­th)	01/01/2018	—
2	Dubai Cars and Automotive Zone (DUCAMZ)	01/01/2018	—
3	Dubai Textile City	01/01/2018	04/04/2021
4	Free Zone Area in Al Quoz	01/01/2018	01/07/2021
5	DAFZA Industrial Park Free Zone — Al Qusais	01/01/2018	—
6	Dubai Aviation City	01/01/2018	—
7	Dubai Airport Free Zone	01/01/2018	—
8	Inte­rna­tional Humanitarian City — Jebel Ali	18/06/2018	—
9	Dubai CommerCity	01/01/2021	—

Nine Dubai entries appear on the list, two of them de-listed, leaving seven live. Dubai Textile City ceased to be a Designated Zone on 4 April 2021, and the Free Zone Area in Al Quoz on 1 July 2021. The practical consequence: any write-up describing Al Quoz or Dubai Textile City as Designated Zones is working from a version of the list more than five years out of date. The words “Dubai Industrial City” do not appear on the list at all.

Why the physical conditions do not help. Article 51(1) of the Executive Regulation — in the consolidated text as amended by Cabinet Decisions No. 46/2020, 24/2021, 88/2021, 99/2022, 100/2024 and 100/2025 — reads: “Any Designated Zone specified by a decision of the Cabinet shall be treated as being outside the State and outside the Implementing States, subject to the following conditions: a. The Designated Zone is a specific fenced geographic area and has security measures and Customs controls in place to monitor entry and exit of individuals and movement of goods to and from the area; b. The Designated Zone shall have internal procedures regarding the method of keeping, storing and processing of Goods therein; c. The operator of the Designated Zone complies with the procedures set by the Authority.”

Conditions (a) to (c) are necessary but not sufficient, and the order matters. The area must first be named in a Cabinet decision. No amount of fencing, security or customs control gives Dubai Industrial City Designated Zone status until the district is named by the Cabinet. The Federal Tax Authority puts it plainly: “Where a Free Zone is not a Designated Zone, it is treated like any other part of the UAE.”

The legal hook for the status is article 50, not article 51, of the VAT Law. Article 50: “A ‘Designated Zone’ that meets the conditions specified in the Executive Regulation of this Decree-Law shall be treated as being outside the State.” Article 51 governs something different — movements between Designated Zones: “Goods may be transferred from one Designated Zone to another Designated Zone without any Tax becoming due.”

> The distinction between VAT Designated Zone status and Free Zone status for corporate tax is fundamental, and neither implies the other. They are two separate lists, made under different instruments and on different criteria. Author’s assessment: the most expensive error in this area is to assume that a free zone licence automatically brings a “tax-free” goods regime. It does not: the Designated Zone list is closed, and Dubai Industrial City is not on it. How the same question resolves in a zone that IS on the list is analysed in Hamriyah Free Zone 2026.

What Sitting Outside a Designated Zone Means for a Manufacturer in Practice

A manufacturer in Dubai Industrial City is in the same VAT position as a factory in Al Quoz or Deira. The mandatory registration threshold is AED 375,000, local supplies are standard-rated at 5 per cent, exports are zero-rated subject to the 90-day condition, and moving goods to JAFZA is not an export.

Transaction	VAT treatment for a Dubai Industrial City resident
Mandatory regi­stra­tion	Threshold AED 375,000 (art. 7(1) of the Executive Regulation); voluntary registration AED 187,500 (art. 8(1))
Local supply within the UAE	5 per cent, standa­rd-ra­ted. No Designated Zone relief is available
Export outside the Implementing States	0 per cent, provided the goods are physically exported or placed under a customs suspension regime within 90 days of the date of supply and the prescribed evidence is retained (art. 30(1) of the Regulation)
Import of raw materials	Import VAT at 5 per cent; a registrant accounts for it under the reverse charge in its return and recovers it under the ordinary input tax rules
Moving goods from Dubai Industrial City to JAFZA or any Designated Zone	Not an export. FTA guidance: “A movement of own goods, or a supply, from mainland UAE to a Designated Zone is not considered to be an export of goods from the UAE. Therefore, such movements and supplies are treated as local movements / supplies” — 5 per cent applies
Moving goods from JAFZA into Dubai Industrial City	An import. FTA guidance: “A movement of goods from a Designated Zone into the mainland UAE is treated as an import of goods into the UAE. Therefore, import VAT is payable by the importer of the goods”
Services	The distinction is irrelevant in any event: even inside a Designated Zone “The place of supply of services is considered to be within the UAE if, under the normal rules, the place of supply would be the Designated Zone”

The JAFZA row is the most frequently misstated line in commercial material about this district. The reasoning “we are in a free zone, so a supply to another free zone is an export” fails twice over: Dubai Industrial City is not a Designated Zone, and a supply from ordinary UAE territory into a Designated Zone is not an export in any case. The practical consequence: a manufacturer planning to sell to a distributor in JAFZA charges 5 per cent, and that sum belongs in the working capital model rather than in the margin.

New from 1 January 2026: a duty to verify the counterparty before deducting. Federal Decree-Law No. 16 of 2025, issued 1 October 2025 and in force 1 January 2026, inserted article 54 bis into the VAT Law. The provision splits into two limbs of different force. Clause 1 is mandatory: “The Authority shall reject the deduction of the Recoverable Input Tax… and the Taxable Person was aware of this relation upon deducting the Recoverable Input Tax.” Clause 2 is discretionary: “The Authority may reject the deduction… and the Taxable Person should, based on circumstances of the supply, have been aware of this relation.” Actual knowledge compels refusal; constructive knowledge permits it. The implementing measure is Federal Tax Authority Decision No. 13 of 2026, issued 22 July 2026.

> Author’s assessment: for an industrial business with a long chain of raw-material suppliers and subcontractors, article 54 bis is not a formality. It shifts part of the risk of a supplier’s conduct onto the buyer, and from 2026 counterparty verification stops being an internal procurement practice and becomes a condition of keeping the deduction.

Corporate Tax: Can a Dubai Industrial City Resident Be a QFZP?

A company registered in Dubai Industrial City can claim Qualifying Free Zone Person (QFZP) status only if the district falls within an area named by a Cabinet decision as a Free Zone. No such list has been published, and the Federal Tax Authority refers the question expressly to the zone authority.

The definitions in the consolidated Corporate Tax Law:

“Free Zone: A designated and defined geographic area within the State that is specified in a decision issued by the Cabinet at the suggestion of the Minister.” “Free Zone Person: A juridical person incorporated, established or otherwise registered in a Free Zone, including a branch of a Non-Resident Person registered in a Free Zone.”

The amendment chain of Decree-Law No. 47 of 2022 — three amendments, all confirmed.

Amending instrument	Issued	In force
Federal Decree-Law No. 60 of 2023	2 October 2023	1 November 2023
Federal Decree-Law No. 40 of 2024	1 October 2024	1 June 2023, retroa­cti­vely
Federal Decree-Law No. 28 of 2025	1 October 2025	15 October 2025

The five QFZP conditions — article 18(1) of Decree-Law No. 47 of 2022. A Qualifying Free Zone Person must: (a) maintain adequate substance in the State; (b) derive Qualifying Income as specified in a Cabinet decision; (c) not have elected into the ordinary regime under article 19; (d) comply with articles 34 and 55 — the arm’s length principle and transfer pricing documentation; and (e) meet any further conditions the Minister prescribes.

Article 18(2): loss of status on breach of any condition takes effect “from the beginning of that Tax Period” — from the start of the tax period, not from the date of the breach.

Article 18(4) caps the 0 per cent regime at “the remainder of the tax incentive period stipulated in the applicable legislation of the Free Zone”, not exceeding fifty years, extendable by the Cabinet. For Dubai Industrial City that points back to article 17 of Law No. 15 of 2014, which grants the clusters a fifty-year exemption — but only if the district sits inside that law’s perimeter.

The instruments in force on Qualifying Income.

Instrument	Issued	Applies from	Status in 2026
Cabinet Decision No. 55 of 2023	30 May 2023	1 June 2023	Repealed by article 10 of Cabinet Decision No. 100 of 2023
Ministerial Decision No. 139 of 2023	1 June 2023	1 June 2023	Repealed by Ministerial Decision No. 265 of 2023
Cabinet Decision No. 100 of 2023	25 October 2023	1 June 2023, retroa­cti­vely	In force
Ministerial Decision No. 265 of 2023	27 October 2023	1 June 2023	Repealed by article 6 of Ministerial Decision No. 229 of 2025
Ministerial Decision No. 229 of 2025	28 August 2025	1 June 2023, retroa­cti­vely	In force

Three of the five instruments in this chain are repealed, and all three continue to be cited as current in industry material. Qualifying Income in 2026 is governed by Cabinet Decision No. 100 of 2023 read with Ministerial Decision No. 229 of 2025 (and, for commodity exchanges and price reporting agencies, with Ministerial Decision No. 230 of 2025, issued the same day); Ministerial Decision No. 229 of 2025 itself applies retroactively from 1 June 2023 under its article 7. The practical consequence: any tax position built on Cabinet Decision No. 55, or on Ministerial Decision No. 139 or No. 265, rests on a repealed instrument — a defect in the position in its own right, regardless of whether the substance happens to coincide.

The categories of Qualifying Income — article 3(1) of Cabinet Decision No. 100 of 2023: “(a) Income derived from transactions with a Free Zone Person, except for income derived from Excluded Activities. (b) Income derived from transactions with a Non-Free Zone Person, but only in respect of Qualifying Activities that are not Excluded Activities. (c) Income derived from the ownership or exploitation of Qualifying Intellectual Property… (d) Any other income provided that the Qualifying Free Zone Person satisfies the de minimis requirements under Article (4) of this Decision.”

The decisive qualification to limb (a) — article 3(2) and 3(3) of the same decision: “For the purposes of paragraph (a) of Clause (1) of this Article, income will be considered as derived from transactions with a Free Zone Person where that Free Zone Person is the Beneficial Recipient of the relevant services or Goods”; and “the term ‘Beneficial Recipient’ shall mean a Person who has the right to use and enjoy the service or the Good and does not have a contractual or legal obligation to supply such service or Good to another person”. What this means in practice: limb (a) carries neither a Qualifying Activity condition nor a Designated Zone condition — it is bounded only by the Excluded Activities and by the requirement that the buyer be the end recipient.

Rates. For an ordinary taxable person, 0 per cent up to the threshold and 9 per cent above it; article 2 of Cabinet Decision No. 116 of 2022 sets the threshold at AED 375,000. For a QFZP, 0 per cent on Qualifying Income and 9 per cent on taxable income that is not qualifying.

Small Business Relief is not available to a Qualifying Free Zone Person. Article 3 of Ministerial Decision No. 73 of 2023 expressly excludes “A Qualifying Free Zone Person” from those who may elect it. The revenue threshold for the relief is AED 3,000,000.

> A 2026 change worth knowing: the relief has been extended. Ministerial Decision No. 131 of 2026, issued 29 July 2026, amended article 2(2) of Ministerial Decision No. 73 of 2023 so that the threshold applies to tax periods ending on or before 31 December 2029, in place of the 31 December 2026 sunset previously cited. The practical consequence for Dubai Industrial City: a small manufacturer that does not claim QFZP status, or that has elected out under article 19, gains three further years of relief; for a QFZP it changes nothing, since the relief is closed to it by definition.

Manufacturing Versus Distribution: The Fork That Decides Everything

Manufacturing, processing and logistics services are Qualifying Activities with no Designated Zone condition attached. Distribution qualifies only “in or from a Designated Zone”. For a Dubai Industrial City resident that means manufacturing income can be taxed at 0 per cent while distribution income cannot qualify through the Qualifying Activity route. The qualification that changes the answer for a trading model: the Designated Zone condition operates only inside limb (b) of article 3(1) of Cabinet Decision No. 100 of 2023 — transactions with a Non-Free Zone Person. Limb (a) — transactions with a Free Zone Person who is the Beneficial Recipient of the goods — requires neither a Qualifying Activity nor a Designated Zone.

The list of Qualifying Activities — article 2(1) of Ministerial Decision No. 229 of 2025, fourteen items:

“a. Manufacturing of goods or materials. b. Processing of goods or materials. c. Trading of Qualifying Commodities. d. Holding of shares and other securities for investment purposes. e. Ownership, management and operation of Ships. f. Reinsurance services. g. Fund management services. h. Wealth and investment management services. i. Headquarter services to Related Parties. j. Treasury and financing services to Related Parties or for its own account. k. Financing and leasing of Aircrafts. l. Distribution of goods or materials in or from a Designated Zone. m. Logistics services. n. Any activities that are ancillary to the Qualifying Activities specified in paragraphs (a) to (m) of this Clause.”

The definitions of manufacturing and processing — article 2(3):

•          Manufacturing: “Manufacturing of goods or materials includes the production, improvement or assembly of products and materials from raw materials or components.”

•          Processing: “Processing of goods or materials includes the preparation, treatment, transformation or conversion of goods or materials into another form of good or material for commercial or industrial use or sale.”

The distribution condition — the same provision, but carrying a proviso that manufacturing does not:

“Distribution of goods or materials in or from a Designated Zone, includes the buying and selling of goods, materials, component parts or any other items that are tangible or movable and may include the importation, storage, inventory management, handling, transportation and exportation of such goods or materials or parts thereof, provided that such activities are conducted in or from a Designated Zone, and the goods or materials entering the State are imported through the Designated Zone…”

Activity carried on in Dubai Industrial City	Can the income be Qualifying Income?
Ma­nufactu­ring of goods and materials	Yes. No Designated Zone condition
Processing of goods and materials	Yes. No Designated Zone condition
Logistics services	Yes. No Designated Zone condition
Di­stri­bution of goods to a Non-Free Zone customer	No. Under the article 3(1)(b) route the activity must be conducted “in or from a Designated Zone”, and Dubai Industrial City is not one
Di­stri­bution of goods to a Free Zone Person who is the Beneficial Recipient	Yes. Under the article 3(1)(a) route, with no Qualifying Activity and no Designated Zone condition
Ownership or exploitation of immovable property, other than Commercial Property in a Free Zone in a transaction with a Free Zone Person	No. An Excluded Activity

The substance rule closes the obvious workaround. Article 8 of Cabinet Decision No. 100 of 2023: “A Qualifying Free Zone Person shall undertake its core income-generating activities in a Free Zone or a Designated Zone, depending on where such activities are required to be conducted, and having regard to the level of the activities carried out, have adequate assets, an adequate number of qualified full-time employees in a Free Zone or a Designated Zone depending on where such activities are required to be conducted, and incur an adequate amount of operating expenditures, in relation to each activity.”

The Federal Tax Authority’s own worked example shows how this cuts against the taxpayer. Its Free Zone Persons guide describes a company with a warehouse in a Designated Zone whose registered office, employees and actual distribution activity sit in a free zone that is not a Designated Zone. The FTA’s conclusion: “The core income-generating activities in relation to the Qualifying Activity of distribution must be performed in a Designated Zone” — so the company fails on the Qualifying Activity route. The example does not stop there, and its second half decides the outcome. The same example continues: “If however, all the customers of Company O are Free Zone Persons who are the Beneficial Recipients of Company O’s Goods, Company O would be able to benefit from the 0% Corporate Tax rate on its Qualifying Income on the basis that its Business involves transacting with Free Zone Persons.” The practical consequence: renting a warehouse in JAFZA while running purchasing and sales from an office in Dubai Industrial City is not enough for the Qualifying Activity route — but the same company reaches 0 per cent if its customers are themselves Free Zone Persons and the Beneficial Recipients of the goods.

> Author’s assessment: this is the central economic conclusion about the district. Dubai Industrial City is a rational choice for a manufacturing model, where 0 per cent is achievable without a Designated Zone. It is structurally unsuited to a trading and distribution model aimed at mainland and overseas buyers, because the restriction attaches to territory rather than to how transactions are papered. The one workaround that actually works is commercial rather than contractual: the customer mix. Where the counterparties are themselves Free Zone Persons and the Beneficial Recipients of the goods, the income qualifies under limb (a) with no Designated Zone condition at all. A company with a mixed model — manufacturing while also reselling third-party goods to mainland buyers — lands in the most awkward configuration of all: the manufacturing revenue qualifies, the trading revenue does not, and the second begins consuming the de minimis allowance.

De Minimis, Audit and the Five-Year Disqualification

The de minimis threshold is 5 per cent of total revenue or AED 5,000,000, whichever is lower. Breaching it strips QFZP status from the beginning of the tax period and for four further tax periods.

The threshold — article 3 of Ministerial Decision No. 229 of 2025:

“the de minimis requirements shall be considered satisfied where the non-qualifying Revenue derived by the Qualifying Free Zone Person in a Tax Period does not exceed 5% (five percent) of the total Revenue of the Qualifying Free Zone Person in that Tax Period or AED 5,000,000 (five million dirhams), whichever is lower.”

The words “whichever is lower” invert the intuition, and most of the errors in this area rest on them.Below AED 100,000,000 of total revenue the binding constraint is the 5 per cent; above AED 100,000,000 it is the absolute AED 5,000,000. A worked example: a manufacturer with revenue of AED 400,000,000 may have no more than AED 5,000,000 of non-qualifying revenue — 1.25 per cent of turnover, not 5 per cent.

The consequence of a breach — article 5(2) of Ministerial Decision No. 229 of 2025:

“A Qualifying Free Zone Person that at any particular time during a Tax Period fails to meet any of the conditions… shall cease to be a Qualifying Free Zone Person from the beginning of the relevant Tax Period and for the subsequent (4) four Tax Periods.”

That is a five-year exclusion from the 0 per cent regime, not a one-off tax charge for the year of the breach. For an industrial business on a long investment cycle the sanction is out of all proportion to the tax at stake in any single year. Author’s assessment: this is exactly where a Dubai Industrial City resident’s risk is concentrated, because its distribution revenue is non-qualifying by definition and accumulates against the allowance automatically rather than through any error.

Audited accounts are mandatory. Article 5(1)(b) of Ministerial Decision No. 229 of 2025 requires a Qualifying Free Zone Person to prepare audited financial statements in accordance with Ministerial Decision No. 84 of 2025 “and any decision that amends or replaces it”.

A mainland permanent establishment is taxed separately. Article 5 of Cabinet Decision No. 100 of 2023: “Income attributable to a Domestic Permanent Establishment or a Foreign Permanent Establishment of the Qualifying Free Zone Person shall be considered Taxable Income and taxed in accordance with paragraph (b) of Clause 2 of Article 3 of the Corporate Tax Law” — that is, at 9 per cent — with the establishment’s profit computed as if it were “a separate and independent Person that is a Related Party of the Qualifying Free Zone Person”.

The global minimum tax. Cabinet Decision No. 142 of 2024, issued 31 December 2024, imposes a top-up to a minimum rate of 15 per cent on groups with annual consolidated revenue of EUR 750 million or more in at least two of the four preceding financial years, and applies to financial years beginning on or after 1 January 2025. The Commentary and Agreed Administrative Guidance were adopted by Ministerial Decision No. 96 of 2026.

> For a Dubai Industrial City resident this matters only if it belongs to a group of EUR 750 million scale. The mechanics are that a QFZP keeps its 0 per cent under the Corporate Tax Law while the group’s UAE effective rate is brought up to 15 per cent by a separate charge. A caveat: neither the Federal Tax Authority nor the Ministry of Finance has published guidance describing the interaction of the top-up with QFZP status, and what is set out here is a reading of article 3(3) of Decree-Law No. 47 of 2022 together with Cabinet Decision No. 142 of 2024, not a quotation of an official position. A standalone mid-sized manufacturer falls outside the regime.

Customs: Duty, the Industrial Exemption and the Customs Warehouse

The GCC common customs tariff is 5 per cent of CIF value on goods imported from outside the customs union. Whether Dubai Industrial City sits inside or outside the customs territory could not be established from published sources, and this analysis asserts neither.

The rate and the base, from official sources. The UAE Government portal: “The rate of customs duty is 5 per cent of the value of goods plus Cost Freight Insurance. It is 50 per cent on alcohol and 100 per cent on cigarettes.” Dubai Customs’ own guide: “The common customs tariff of the GCC Customs Union shall be %5 on CIF value of all foreign goods imported from outside of the Customs union.” The GCC customs union has applied since 1 January 2003.

The general free zone principle, from the official portal: “free zone licencees are allowed to import goods or equipment into the free zone from a foreign country without payment of customs duties… Customs duty is only paid when goods are moved out of the free zone; that is, imported into the UAE.”

Whether that principle reaches Dubai Industrial City does not follow from the published sources, and this needs saying plainly. Dubai Industrial City is absent from Dubai Customs’ list of customs centres; TECOM appears there only inside the combined entry “Jebel Ali & TECOM Customs Center”. Dubai Customs’ 2025 Service Guide (version 9) contains no customs definition of a free zone, no list of customs free zones, and no mention of Dubai Industrial City. Author’s assessment: this question cannot be settled by analogy — it should be closed with a written confirmation from Dubai Customs before a lease is signed, because the whole raw-material import model turns on the answer.

And separately: customs free zone status and VAT Designated Zone status are different things. An area can be a customs free zone without being a VAT Designated Zone. The absence of Dubai Industrial City from the Designated Zone list therefore does not prove that the district lies inside the customs territory.Conflating the two is the second most common error in material about this district, after conflating building-control jurisdiction with free zone status.

What is available to a manufacturer regardless of the district’s status.

Mechanism	Substance
National Industrial Licence	Dubai Customs’ guide: “National Industrial License holders can claim Duty exemptions for their machineries and raw material imported for manufacturing purposes”, subject to ministerial approval. A point on who actually approves it today: the Dubai Customs text quoted (Customer Guide, version 3.03) names the Ministry of Economy, but the federal policy on customs exemption for industrial inputs of 11 November 2022 places the function with the Ministry of Industry and Advanced Technology (MoIAT), which runs the service. This is the principal duty-relief route for an industrial tenant and does not depend on Designated Zone status
Customs Warehouse	“Import to CW” is a declaration type in its own right alongside “Import to Local”, “Import to FZ”, transit and temporary admission. It gives on-site duty suspension
Customs suspension regimes under the GCC Common Customs Law	These simu­lta­neously unlock VAT zero-rating under article 30(1) of the Executive Regulation
Duty drawback on re-export	The standard drawback mechanism
The Request Customs Duty Exemption e-service	Exists on the Dubai Customs portal as the filing channel. The substantive criteria are set federally: the policy on customs exemption for industrial inputs of 11 November 2022 provides for on-site inspection of the plant, an approved factory quota and periodic reporting on processing and value added

> The practical consequence for an industrial model. Even if Dubai Industrial City turns out to sit inside the customs territory, the National Industrial Licence and the customs warehouse together answer the duty question on raw materials and plant without relying on the district’s status. For a manufacturer that means customs uncertainty is manageable, whereas VAT Designated Zone uncertainty is not — the list is closed and there is nothing to work around it with.

Mainland Access: Executive Council Resolution No. 11 of 2025

Since 2025 a free zone company may carry on business in mainland Dubai on obtaining a licence or permit from the Department of Economy and Tourism. Article 12 of the Resolution prices only two things: AED 10,000 a year for a licence for a branch located inside the free zone that operates outside it, and AED 5,000 for a temporary permit. A mainland branch under article 5 is charged at the Department of Economy and Tourism’s ordinary tariff, which the Resolution does not fix. The profit of the mainland presence is taxed at 9 per cent.

The instrument: Executive Council Resolution No. (11) of 2025 Regulating the Conduct of Free Zone Establishments’ Activities within the Emirate of Dubai. Issued 3 March 2025. Article 15: “This Resolution will be published in the Official Gazette and will come into force on the day on which it is published.”

Scope — article 2: “The provisions of this Resolution apply to the Establishments wishing to conduct their Activities outside of Free Zones. This Resolution does not apply to financial Establishments licensed to operate in the Dubai International Financial Centre.”

The article 1 definitions reach the DDA: “Licensing Authority: Any authority legally mandated to supervise a Free Zone and license the Establishments operating therein.” The Dubai Development Authority has included Executive Council Resolution No. (11) of 2025 in its own legal database, which confirms that the instrument applies to its licensees.

Three routes — articles 5, 6 and 7.

Route	What it permits	Annual cost
A licence for a mainland branch(art. 5)	A physical presence outside the zone	The Department of Economy and Tourism’s ordinary tariff. The Resolution fixes no sum; article 5(a)(6) requires only that “the prescribed fees” be paid
A licence for a branch located in the free zone but carrying on activities within the emirate (art. 6)	Mainland activity without mainland premises	AED 10,000
A temporary activity permit (art. 7)	Valid for not more than six months	AED 5,000

Licences run for one year and are renewable (art. 4).

A material concession on staff — article 8: the establishment “may engage its existing workforce registered on the Free Zone portal, and may continue to benefit from all Free Zone employment privileges”. The practical consequence: no separate recruitment is required for the mainland activity.

A mandatory condition — separate books. Article 3(b) requires separate financial records for the activities conducted outside the zone.

Transition — article 13: the window has already closed. Companies already operating outside the zone without the proper permissions were given one year to regularise, with the Director General able to extend it once for the same period. The Resolution took effect on publication (art. 15) and was issued on 3 March 2025, so the window closed on or about 3 March 2026; no extension is recorded on dlp.dubai.gov.ae. As at August 2026 a free zone company trading on the mainland without a licence or permit is outside the grace period, not inside it.

The list of economic activities that article 9 directs the Department of Economy and Tourism to issue within six months could not be located. It appears neither on the Dubai legislation portal nor in the DDA’s legal database, and no amendment or implementing decision has surfaced as at August 2026. This analysis records that as an open question: without the approved list, the scope of permitted mainland activity is settled case by case on application to the Department of Economy and Tourism (DET).

The tax consequence of a mainland presence. Article 3(1) of Cabinet Decision No. 100 of 2023 excludes from Qualifying Income any profit attributable to a permanent establishment, and article 5 of the same decision brings it into taxable income at 9 per cent. QFZP status is not lost: a separately taxed slice arises, not a disqualification.

The separate-books requirement in article 3(b) of the Resolution and the separate-entity computation in article 5 of Decision No. 100 line up, which is convenient. One set of management accounts satisfies both. A caveat: no FTA or Ministry of Finance guidance on the interaction of Resolution No. 11 of 2025 with QFZP status has been published; what is set out here is a reading of the two instruments together. The choice between a mainland and a free zone presence is analysed in Free Zone or Mainland in the UAE in 2026.

> Mainland activity does not affect Designated Zone status at all, because that status attaches to the area rather than to the taxpayer. For Dubai Industrial City the point is moot: there is nothing to lose.

The Industrial Licence and the Federal Registry: Two Separate Obligations

A manufacturer in Dubai Industrial City must both obtain an industrial licence from the competent licensing authority and enter its data in the federal Industrial Registry maintained by the Ministry of Industry and Advanced Technology. These are two distinct obligations, and being in a free zone does not relieve the second.

The instrument: Federal Decree-Law No. (25) of 2022 Regarding the Regulation and Development of the Industry.Issued 26 September 2022, published 28 September 2022 in Official Gazette No. 736, in force 2 January 2023.

The decisive provision — article 3(1): “The provisions herein shall apply to all industrial establishments, including industrial establishments located in free zones in the State.”

That wording removes the practical significance of the uncertainty over Dubai Industrial City’s status, so far as industrial regulation is concerned. A manufacturer is caught by the federal industry law whether or not the district is a free zone. The practical consequence: the argument about the district’s status affects tax and customs, but not the industrial licence or the registry.

Who issues the licence. Article 5(1): “The Licensing Authority shall be responsible for issuing, renewing, amending, suspending and cancelling industrial licences for industrial establishments within its jurisdiction.” Article 1 defines the Licensing Authority as “The local authority or free zone authority competent to issue an industrial licence for an industrial establishment”. The industrial licence is therefore issued locally, not by the Ministry.

The federal registry. Article 6(1): “A registry called the ‘Industrial Registry’ shall be established at the Ministry, including data and information related to licensed industrial establishments.” The Ministry describes it as a digital platform on which companies register their information annually, citing Federal Decree-Law No. 25 of 2022 and its Executive Regulation as the basis.

There is no blanket free zone exemption. Article 3(4) allows the Cabinet to exempt particular industrial sectors, but the law contains no general carve-out for free zones.

The industrial policy the district sits inside.

Programme	Substance
Operation 300bn	Raising industry’s contribution to GDP from AED 133 billion to AED 300 billion by 2031. Eleven sectors in three tiers: stimulating growth (food and beverage and agri-tech, pharma­ceu­ticals, electrical equipment and electronics); advanced manufacturing (petro­che­micals and chemicals, rubber and plastics, machinery and equipment); industries of the future (hydrogen, medical technology, space technology)
National In-Country Value (ICV)	A certificate scoring a supplier’s contribution to the local economy; certified suppliers gain advantages in procurement and tenders. The Ministry’s page states neither a launch date nor whether participation is mandatory
Dubai Industrial Strategy 2030	Launched in June 2016. Six priority sub-sectors, 75 ini­tiati­ves, and a projected additional AED 160 billion by 2030
Dubai Economic Agenda D33	Launched 4 January 2023. Doubling the size of Dubai’s economy over a decade; foreign trade from AED 14.2 trillion to AED 25.6 trillion; foreign direct investment from an average of AED 32 billion to AED 60 billion a year; includes “launching Dubai’s plan for green and sustainable manu­factu­ring”

> No formal update to either Dubai Industrial Strategy 2030 or D33 was identified for 2025–2026. The activity around the district over that period is operational rather than strategic: TECOM Group’s acquisition of 138 plots spanning 33 million sq ft, and Dubai Industrial City attracting AED 1.7 billion of investment over twelve months. TECOM Group reported record revenue of AED 2.9 billion for 2025, with recurring net profit up 20 per cent. How the federal industrial incentives and the ICV programme work is analysed in Make it in the Emirates 2026.

The Other Federal Obligations of a Dubai Industrial City Resident

Beyond tax and the industrial licence, a manufacturer in Dubai Industrial City carries four federal obligations: corporate tax registration within the prescribed window, maintenance of a beneficial ownership register, compliance with the anti-money-laundering regime, and — for pre-2023 periods only — economic substance reporting.

Corporate tax registration. Federal Tax Authority Decision No. 3 of 2024 was issued 22 February 2024 and has applied from 1 March 2024. For resident juridical persons incorporated, established or recognised before 1 March 2024 — the trigger is incorporation, not tax registration — the deadline runs from the month in which the licence was first issued, and the steps are not uniformly monthly: January and February give 31 May 2024, March and April 30 June, May 31 July, June 31 August, July 30 September, August and September 31 October, October and November 30 November, and December 31 December 2024. For persons incorporated in the UAE on or after 1 March 2024 the window is three months from incorporation; for a foreign juridical person effectively managed and controlled in the State it is three months from the end of its financial year.

The penalty for missing it is AED 10,000. Cabinet Decision No. 75 of 2023, as amended by Cabinet Decision No. (10) of 2024, applies from 1 March 2024; item 14 of the schedule of violations imposes AED 10,000 for failure to file a tax registration application within the prescribed timeframe. A necessary addition, without which the figure misleads: on 7 May 2025 the Federal Tax Authority announced a waiver of that penalty. The condition is filing the first tax return (or annual declaration) “within a period not exceeding seven (7) months from the end of their first Tax Period” instead of nine. A penalty already paid is refunded where the condition is met: “the paid penalty will be refunded and the amount will be credited to the taxable person’s account with the Authority.” The penalty instrument itself has not been repealed.

Beneficial ownership. Cabinet Decision No. 109 of 2023, issued 6 November 2023 and in force “the day following the date of its publication”, repealed Cabinet Resolution No. 58 of 2020. The obligations are to maintain a Real Beneficiary Register (art. 8) and a Partners or Shareholders Register (art. 10), each updated within fifteen days of being informed of a change.

The article 3 exclusions cover wholly government-owned companies and Financial Free Zones — meaning DIFC and ADGM. The Dubai Development Authority is not a financial free zone, so a DDA licensee in Dubai Industrial City is fully within the scope of the beneficial ownership rules. Penalties sit in Cabinet Decision No. 132 of 2023. The most recent DDA circular on the point is Circular 670 of 3 June 2026 on the beneficial owner declaration process.

Anti-money laundering. The regime was renewed in late 2025: Federal Decree-Law No. (10) of 2025 was issued 30 September 2025, published in Official Gazette No. 808 the same day, and came into force on 14 October 2025; its executive regulation is Cabinet Resolution No. (134) of 2025. Both are published on the federal legislation portal uaelegislation.gov.ae and apply to DDA licensees on the same footing as other reporting entities.

Economic substance: the regime is closed going forward, but not repealed retrospectively. Cabinet Decision No. 98 of 2024 amended Cabinet Decision No. 57 of 2020, and the Ministry of Finance described the effect as lifting economic substance reporting requirements for financial years ending after 31 December 2022.

The precise formulation: the economic substance regime has not been repealed; it ceased to apply prospectively. Notification and reporting obligations, and exposure to penalties, remain for financial years from 1 January 2019 to 31 December 2022; the position on penalties imposed for later periods needs a caveat. Their cancellation and refund is not confirmed by a primary text: the full text of Cabinet Decision No. 98 of 2024 is closed to automated access, and the Ministry of Finance announcement of 14 October 2024 does not mention them and says the opposite for earlier years: companies “remain obligated to fulfill compliance obligations for prior years, respond to regulatory authority or Federal Tax Authority information requests, and pay any penalties imposed by the Federal Tax Authority”. A sourcing caveat: as at August 2026 the Federal Tax Authority and Ministry of Finance pages on the regime still describe the obligation as live and still cite Decision No. 57 of 2020. For the current position, rely on the text of Decision No. 98 of 2024 and the Ministry’s announcement of it, not on those pages.

Workforce obligations. An industrial operation means people, and with them UAE employment law and Emiratisation requirements. Hiring the first employee is covered in How to Hire Your First Employee in the UAE, and the quotas and penalties in Emiratisation 2026.

How It Compares for an Industrial Project

The decisive difference between UAE industrial sites is not rent but whether the site carries VAT Designated Zone status. Dubai Industrial City does not; JAFZA does; and for a trading and distribution model aimed at mainland customers that is the governing factor.

Parameter	Dubai Industrial City	JAFZA	DAFZA — Al Qusais	Hamriyah (Sharjah)	RAKEZ (Ras Al Khaimah)
Regulator and licensor	Dubai Development Authority	The JAFZA authority	The DAFZA authority	The Hamriyah authority	The RAKEZ authority
VAT Designated Zone status	No	Yes — “Jebel Ali Free Zone (No­rth-Sou­th)” from 01/01/2018	Yes — “DAFZA Industrial Park Free Zone — Al Qusais” from 01/01/2018	Yes	Yes
Di­stri­bution as a Qualifying Activity	Una­vaila­ble — a Designated Zone is required	Available	Available	Available	Available
Ma­nufactu­ring as a Qualifying Activity	Available	Available	Available	Available	Available
Sector profile	Six clusters: base metals, machinery, minerals, food and beverage, transport, chemicals	Port and heavy logistics	Airport and light industry	Port and heavy industry	Generalist, with an industrial segment

The practical conclusion from the table fits in one sentence: if the model is trading and the customers sit outside the free zones, Designated Zone status matters more than any saving on rent. The difference between 0 and 9 per cent on distribution revenue is not of the same order as a difference in the rent per square foot. Author’s assessment: Dubai Industrial City is not competing with JAFZA for the distributor. It is competing with industrial sites for the manufacturer who needs large plots, 4 megawatts per plot, a rail freight terminal and worker accommodation on site. The profile of a Designated Zone geared to heavy industry is analysed in Hamriyah Free Zone 2026; a generalist alternative with an industrial segment in RAKEZ 2026; and an airport zone with developed warehousing and customs infrastructure in DAFZA: The Free Zone at Dubai Airport.

What Dubai Industrial City lacks among its Dubai peers, and what that changes. Of the seven live Dubai entries on the Designated Zone list, four are logistics and aviation sites, one is automotive re-export, one is humanitarian supply and one is e-commerce. Apart from JAFZA, Dubai has effectively no industrial site that combines large land plots with Designated Zone status. That is why the choice for a manufacturer in Dubai usually reduces to JAFZA against Dubai Industrial City rather than to a comparison of ten zones.

Step by Step: From Checking the Status to Starting Production

Order matters more than speed here: two questions — free zone status for corporate tax, and the customs perimeter — should be closed in writing before a lease is signed, not after.

1.        Fix the business model before choosing the site. A manufacturing model and a trading-and-distribution model point to different zones. Dubai Industrial City suits the first, and the second only where the customers are Free Zone Persons who are themselves the Beneficial Recipients of the goods.

2.        Ask the Dubai Development Authority for written confirmation that the company is being registered in a Free Zone for corporate tax purposes. This is exactly what the Federal Tax Authority’s guide directs: “All taxpayers should check with their respective Free Zone Authority to confirm if they operate in a Free Zone or Designated Zone for Corporate Tax purposes.”

3.        Ask Dubai Customs for written confirmation of the plot’s customs status. Dubai Industrial City is absent from the list of customs centres, and the question cannot be settled by analogy.

4.        Do not plan around VAT Designated Zone status. Dubai Industrial City is not on the list, the list is closed, and there is nothing to work around it with.

5.        Test whether the DDA’s licence-categories decision applies. Decision No. 1 of 2021 covers ten named districts, and Dubai Industrial City is not among them; minimum capital and the category list must be confirmed separately.

6.        Obtain a licence quotation from the DDA in writing for the specific activity. The published schedule — an AED 3,500 registration fee plus an activity-based licence fee — belongs to the creative clusters route.

7.        Get the land or warehouse offer directly. The district publishes no prices, and it can only be compared with zones that publish packages on the basis of individual offers.

8.        Budget transaction and infrastructure costs separately from the rent — connecting up to 4 MW per plot, access roads, yards, worker accommodation.

9.        Obtain an industrial licence from the competent licensing authority and, separately, enter the data in MoIAT’s federal Industrial Registry, renewing it annually. Both obligations apply to establishments in free zones under article 3(1) of Federal Decree-Law No. 25 of 2022.

10.    Register for corporate tax within the window set by FTA Decision No. 3 of 2024. Missing it costs AED 10,000 under item 14 of the schedule of violations.

11.    Split revenue into qualifying and non-qualifying from the first day of the accounting system. Manufacturing and logistics revenue qualifies; distribution revenue qualifies only on sales to Free Zone Persons who are the Beneficial Recipients, and does not on sales to anyone else. The ledger has to be cut by customer type, not only by activity.

12.    Monitor the de minimis allowance on the “whichever is lower” rule: 5 per cent of total revenue or AED 5,000,000. Above AED 100,000,000 of revenue the absolute figure binds.

13.    Put audited financial statements in place — this is a condition of QFZP status under article 5(1)(b) of Ministerial Decision No. 229 of 2025, not an optional exercise.

14.    If mainland activity is planned, take the Executive Council Resolution No. 11 of 2025 route and set up the separate books required by article 3(b) at the outset rather than retrospectively.

15.    Build a counterparty verification procedure into the VAT deduction process, reflecting article 54 bis in force from 1 January 2026 and FTA Decision No. 13 of 2026.

16.    Maintain the beneficial owner register and the shareholders register, updating each within fifteen days of being informed of a change.

17.    Check economic substance exposure for financial years 2019 to 2022 — the regime remains live for those periods and the obligations have not been lifted.

18.    Plan the workforce side early — UAE employment law, Emiratisation quotas and staff accommodation are part of the capital plan in an industrial model, not an operational detail.

Common Mistakes and What They Cost

Mistake 1. Treating the district’s free zone status as settled and never confirming it in writing. No published Dubai instrument names the district, and the Federal Tax Authority’s guide refers the question expressly to the zone authority. Cost: the entire 0 per cent calculation rests on a premise that no document supports on review, and it cannot be repaired retrospectively.

Mistake 2. Taking free zone status on trust because the district belongs to TECOM Group. No published Dubai instrument names Dubai Industrial City as a free zone, and the DDA’s licence-categories decision does not extend to it. Cost: QFZP status is the difference between 0 and 9 per cent on all qualifying profit. If it emerges two years in that the basis for the status was never there, the exposure is not one year’s tax but the whole period, plus penalties.

Mistake 3. Planning around VAT Designated Zone treatment. Dubai Industrial City is not on the list. Cost: 5 per cent on all local supplies, including supplies to JAFZA that were mistakenly modelled as zero-rated exports. On AED 100,000,000 of turnover that is AED 5,000,000 of VAT absent from the working capital plan.

Mistake 4. Treating distribution from Dubai Industrial City as a Qualifying Activity. Item (l) of article 2(1) of Ministerial Decision No. 229 of 2025 requires the activity to be conducted “in or from a Designated Zone”. Cost: distribution revenue from sales to customers outside the free zones becomes non-qualifying and consumes the de minimis allowance. On a breach, QFZP status is lost from the beginning of the tax period and for four further periods — five years in all.

Mistake 5. Assuming a warehouse in a Designated Zone solves the distribution problem. Article 8 of Cabinet Decision No. 100 of 2023 requires the core income-generating activities and the staff to sit where the activity is required to be conducted. The FTA’s own worked example describes precisely this structure and finds it non-compliant on the Qualifying Activity route. Cost: the rent on a warehouse in another zone is incurred and the tax outcome is not achieved. The mirror image of the same mistake is missing the second paragraph of that same FTA example, where 0 per cent survives if every customer is a Free Zone Person and the Beneficial Recipient of the goods — in which case the warehouse in another zone was never needed.

Mistake 6. Applying the de minimis threshold as “5 per cent” without the “whichever is lower” qualifier. Above AED 100,000,000 of revenue the AED 5,000,000 absolute cap binds. Cost: a manufacturer with AED 400,000,000 of turnover working to 5 per cent believes it can carry AED 20,000,000 of non-qualifying revenue when the real limit is AED 5,000,000. A fourfold breach, and the consequence is a five-year disqualification.

Mistake 7. Citing Cabinet Decision No. 55 of 2023, or Ministerial Decision No. 139 or No. 265. All three are repealed. Cost: a tax position resting on a repealed instrument is defective regardless of whether the substance coincides, and on audit it has to be defended on form rather than on merits — from a weak starting point.

Mistake 8. Relying on the FTA’s Free Zone Persons guide as a current source. The CTGFZP1 edition is dated May 2024 and cites the repealed Ministerial Decision No. 265 of 2023. Cost: where the guide and the Ministerial Decision in force diverge, the Decision governs, and a position built on the guide may not stand.

Mistake 9. Carrying the AED 10,000 minimum capital across to Dubai Industrial City. The figure comes from article 15 of Decision No. 1 of 2021, which applies to ten other districts. Cost: a wrong capital structure at incorporation is corrected through amended constitutional documents and repeated approvals — that is, in time rather than money, and in an industrial project time is tied to the construction programme.

Mistake 10. Conflating the district’s customs status with VAT Designated Zone status. They are different lists under different instruments. Cost: the wrong import model for raw materials. An error in the taxpayer’s favour brings assessed duty and VAT with penalties; an error against it means duty paid that need not have been, had the National Industrial Licence route been available.

Mistake 11. Assuming that being in a free zone displaces industrial legislation. Article 3(1) of Federal Decree-Law No. 25 of 2022 expressly extends the law to “industrial establishments located in free zones in the State”. Cost: operating without an industrial licence and without an entry in the federal registry is a breach of federal law, not a zone formality, and it cannot be cured by agreement with the landlord.

Mistake 12. Budgeting off TECOM Group’s segment metrics as though they described the district. Gross leasable area, occupancy and WALT are disclosed by group segment rather than by district, and the Land Leasing segment covers more than Dubai Industrial City. Cost: a financial model built on group averages instead of the terms of a specific plot diverges from the actual lease on term, rate and area.

Mistake 13. Building a schedule on published distances to the port and the airport. Neither Dubai Industrial City nor TECOM Group publishes numeric distances. Cost: a logistics model built on property-portal figures, carrying an error in the haulage leg that only surfaces once real shipments start.

Mistake 14. Starting mainland activity without the Resolution No. 11 of 2025 route. Article 13 gives those already operating outside the zone one year to regularise. Cost: beyond the regulatory risk, there are no separate books — and without them the profit of the mainland permanent establishment cannot properly be isolated under article 5 of Cabinet Decision No. 100 of 2023, which puts the whole return in question.

Who Dubai Industrial City Suits, Who It Does Not, and When Professional Review Is Needed

Dubai Industrial City is built for a manufacturer that needs large plots, substantial electrical capacity, a rail freight terminal and worker accommodation on site, and that is untroubled by the absence of VAT Designated Zone status.

It suits:

•          manufacturing and processing businesses — their activity qualifies with no Designated Zone condition attached;

•          energy-intensive projects — the stated capacity of up to 4 MW per plot is published as a district parameter;

•          operations with large workforces — more than 56,000 beds in accommodation villages on site;

•          companies in the six target clusters — base metals, machinery, minerals, food and beverage, transport and chemicals;

•          projects built around rail logistics — the Etihad Rail freight terminal sits inside the district;

•          exporters — exports are zero-rated regardless of Designated Zone status, subject to the 90-day condition and the documentary evidence.

It does not suit:

•          trading and distribution companies selling to mainland and overseas buyers — on that route distribution qualifies only “in or from a Designated Zone”, and Dubai Industrial City is not one (sales to Free Zone Persons who are the Beneficial Recipients are the exception);

•          models built on moving goods between free zones free of VAT — a supply from Dubai Industrial City to JAFZA is standard-rated at 5 per cent;

•          companies that need a fixed published cost of entry — commercial terms here are negotiated individually;

•          anyone unwilling to close the status question in writing — neither free zone status for corporate tax nor the customs perimeter follows from the published instruments;

•          purely office-based and service businesses — the district’s profile is industrial, and other DDA districts offer better comparable office terms.

Professional review is needed: in obtaining written confirmation of status from the DDA and from Dubai Customs; in splitting revenue between qualifying and non-qualifying in a mixed model; in computing the de minimis allowance on the “whichever is lower” rule; in structuring mainland activity under Resolution No. 11 of 2025; in choosing between the National Industrial Licence and a customs warehouse for raw-material imports; and in any scenario contemplating a warehouse in a Designated Zone paired with an office in Dubai Industrial City.

Frequently Asked Questions

Is Dubai Industrial City a free zone or not?

No published Dubai instrument names Dubai Industrial City as a free zone. The Dubai Development Authority states on its website that it is responsible for company registration and licensing in TECOM Group’s districts, Dubai Industrial City included. At the same time the DDA’s binding licence-categories decision — Decision No. 1 of 2021 — applies by its own title to ten other districts, and Dubai Industrial City is not mentioned in it. The practical conclusion: the status should be confirmed by a written enquiry to the DDA, exactly as the Federal Tax Authority’s guide directs.

Is Dubai Industrial City a VAT Designated Zone?

No. It does not appear on the Designated Zone list established by Cabinet Decision No. 59 of 2017 as amended through Cabinet Decision No. 81 of 2021. Seven Dubai entries remain live: Jebel Ali Free Zone (North-South), DUCAMZ, DAFZA Industrial Park Free Zone — Al Qusais, Dubai Aviation City, Dubai Airport Free Zone, International Humanitarian City — Jebel Ali, and Dubai CommerCity.

Which industries are located in Dubai Industrial City?

The district is organised into six industrial clusters: base metals, machinery, minerals, food and beverage, transport and chemicals. As at November 2024 TECOM Group reports more than 1,100 resident businesses, and the largest disclosed cluster is food and beverage at 23.5 million sq ft.

Can 0 per cent corporate tax be achieved in Dubai Industrial City?

Yes, for manufacturing activity, if the Qualifying Free Zone Person conditions are met. Ministerial Decision No. 229 of 2025 lists “Manufacturing of goods or materials” and “Processing of goods or materials” as Qualifying Activities with no Designated Zone condition. Distribution income cannot qualify on that route, because item (l) of the same list requires the activity to be conducted “in or from a Designated Zone”. There is a second route, though: limb (a) of article 3(1) of Cabinet Decision No. 100 of 2023 treats income from transactions with a Free Zone Person who is the Beneficial Recipient of the goods as Qualifying Income, with no Qualifying Activity and no Designated Zone condition.

What do a licence and a lease cost in Dubai Industrial City?

Commercial terms are agreed individually rather than off a published tariff. Every offering page ends in a contact form. The Dubai Development Authority publishes, for the FZ-LLC route in the creative clusters, a registration fee of AED 3,500, an activity-based licence fee, and AED 10 each for the Knowledge Dirham and the Innovation Dirham per transaction — but the applicability of that schedule to Dubai Industrial City is not established.

Is customs duty payable on raw materials entering Dubai Industrial City?

Whether the district sits inside or outside the customs territory could not be established from published sources.Dubai Industrial City is absent from Dubai Customs’ list of customs centres. Regardless of the district’s status, a National Industrial Licence holder may claim exemption from duty on plant and raw materials imported for manufacturing, and a customs warehouse gives duty suspension. The base rate is 5 per cent of CIF value.

Can a Dubai Industrial City company sell into mainland Dubai?

Yes, under Executive Council Resolution No. (11) of 2025 of 3 March 2025. Three routes exist: a licence for a mainland branch, a licence for a branch located in the zone conducting activities within the emirate, and a temporary permit of up to six months. The cost is AED 10,000 a year for a licence and AED 5,000 for a permit. The profit of the mainland permanent establishment is taxed at 9 per cent, but QFZP status is not lost.

Is an industrial licence needed in addition to the zone licence?

Yes, and registration in the federal Industrial Registry is required as well. Article 3(1) of Federal Decree-Law No. 25 of 2022 extends the law to “all industrial establishments, including industrial establishments located in free zones in the State”. The industrial licence is issued by the competent local or free zone authority, while the registry is maintained by the Ministry of Industry and Advanced Technology and updated annually.

What is the minimum share capital?

For Dubai Industrial City no figure is set by any published instrument. Regulation 25.1 of the Private Companies Regulations 2016 reads: “The minimum issued fully paid up share capital of a company shall be such amount as the Registrar specifies from time to time.” The AED 10,000 figure comes from article 15 of Decision No. 1 of 2021, which applies to ten other districts.

What happens if the de minimis allowance is exceeded?

Qualifying Free Zone Person status is lost from the beginning of the relevant tax period and for four further tax periods. The allowance is 5 per cent of total revenue or AED 5,000,000, whichever is lower. Above AED 100,000,000 of revenue the absolute figure binds.

Is Small Business Relief available to a Dubai Industrial City resident?

Not to a Qualifying Free Zone Person. Article 3 of Ministerial Decision No. 73 of 2023 expressly excludes “A Qualifying Free Zone Person”. The revenue threshold for the relief is AED 3,000,000, and Ministerial Decision No. 131 of 2026 of 29 July 2026 extended it to tax periods ending on or before 31 December 2029.

Do the economic substance requirements still apply?

They have been lifted for financial years ending after 31 December 2022; for periods from 1 January 2019 to 31 December 2022 the regime remains live. Cabinet Decision No. 98 of 2024 amended Cabinet Decision No. 57 of 2020, and the cancellation and refund of penalties imposed for the later periods is not confirmed by any primary text.

Key Takeaways

•          Dubai Industrial City is a TECOM Group district under the jurisdiction of the Dubai Development Authority, which states that it handles registration and licensing across the group’s districts.

•          No published Dubai instrument names Dubai Industrial City as a free zone, and the DDA’s licence-categories decision applies to ten other districts.

•          Dubai Industrial City is not a VAT Designated Zone; seven Dubai entries on the list remain live.

•          Manufacturing, processing and logistics services are Qualifying Activities with no Designated Zone condition; distribution requires a Designated Zone and cannot qualify in Dubai Industrial City on that route — except for sales to Free Zone Persons who are the Beneficial Recipients of the goods, which qualify under limb (a) of article 3(1) of Cabinet Decision No. 100 of 2023.

•          The de minimis allowance is 5 per cent of revenue or AED 5,000,000, whichever is lower; a breach costs five years without the 0 per cent rate.

•          Cabinet Decision No. 100 of 2023 and Ministerial Decision No. 229 of 2025 are in force; Decisions Nos. 55/2023, 139/2023 and 265/2023 are repealed.

•          Customs duty is 5 per cent of CIF value, and the district’s customs perimeter does not follow from the published sources.

•          Mainland activity is available under Resolution No. 11 of 2025: AED 10,000 for a licence, AED 5,000 for a permit, and 9 per cent on the permanent establishment’s profit.

•          An industrial licence and the federal Industrial Registry are mandatory for free zone establishments too.

Summary

Dubai Industrial City is a TECOM Group industrial district in Dubai, unveiled in November 2004 and one of the twelve districts the Dubai Development Authority describes on its own website as falling under its jurisdiction, with the DDA responsible for company registration and licensing; the district sat in TECOM Group’s Manufacturing Cluster when the group listed on the Dubai Financial Market on 5 July 2022 and hosts more than 1,100 companies across six clusters — base metals, machinery, minerals, food and beverage, transport and chemicals. The emirate-level framework consists of Dubai Law No. 15 of 2014 on creative clusters, issued 27 October 2014 and superseding Law No. 1 of 2000; Decree No. 30 of 2017, which extended the clusters’ urban planning and construction legislation to land owned by Dubai Holding and its affiliates; Law No. 10 of 2018 of 19 September 2018, which renamed the Dubai Creative Clusters Authority the Dubai Development Authority; and Law No. 8 of 2023 of 6 February 2023, which substituted a new article 3 into Law 15/2014 and attached a schedule of twenty-four land plots constituting the free zone — but the words “Dubai Industrial City” appear in none of these instruments, and the binding Decision No. 1 of 2021 on licence categories applies by its own title to ten other districts, so free zone status for corporate tax purposes should be confirmed by written enquiry to the DDA, exactly as the Federal Tax Authority’s Corporate Tax Guide | Free Zone Persons | CTGFZP1 directs. For VAT the position is unambiguous: Dubai Industrial City does not appear on the Designated Zone list established by Cabinet Decision No. 59 of 2017 as amended by Decisions Nos. 35/2018, 43/2019, 34/2021, 63/2021 and 81/2021, on which seven Dubai entries remain live — Jebel Ali Free Zone (North-South), DUCAMZ, DAFZA Industrial Park Free Zone — Al Qusais, Dubai Aviation City, Dubai Airport Free Zone, International Humanitarian City — Jebel Ali and Dubai CommerCity — while Dubai Textile City was removed on 4 April 2021 and the Free Zone Area in Al Quoz on 1 July 2021; local supplies, including supplies to JAFZA, are therefore standard-rated at 5 per cent, the mandatory registration threshold is AED 375,000, exports are zero-rated where the goods leave within 90 days, and from 1 January 2026 article 54 bis, inserted by Federal Decree-Law No. 16 of 2025, allows an input tax deduction to be refused where the prescribed supplier verification was not carried out. For corporate tax the instruments in force are Cabinet Decision No. 100 of 2023 of 25 October 2023 and Ministerial Decision No. 229 of 2025 of 28 August 2025, while Cabinet Decision No. 55 of 2023, Ministerial Decision No. 139 of 2023 and Ministerial Decision No. 265 of 2023 are repealed: manufacturing, processing and logistics services are Qualifying Activities with no Designated Zone condition, whereas distribution qualifies only “in or from a Designated Zone” and therefore cannot qualify for a Dubai Industrial City resident on that route, although limb (a) of article 3(1) of Cabinet Decision No. 100 of 2023 treats income from transactions with a Free Zone Person who is the Beneficial Recipient of the goods as Qualifying Income with no Qualifying Activity and no Designated Zone condition, against a non-qualifying revenue allowance of 5 per cent of total revenue or AED 5,000,000, whichever is lower, with loss of status from the beginning of the tax period and for four further tax periods on a breach. The corporate tax rate is 0 per cent on Qualifying Income and 9 per cent on other taxable income, the ordinary threshold is AED 375,000 under Cabinet Decision No. 116 of 2022, Small Business Relief with its AED 3,000,000 revenue threshold is closed to a Qualifying Free Zone Person and was extended by Ministerial Decision No. 131 of 2026 to tax periods ending on or before 31 December 2029, and the global top-up to 15 per cent under Cabinet Decision No. 142 of 2024 applies to groups with EUR 750 million or more of revenue for financial years beginning on or after 1 January 2025. Customs duty is 5 per cent of CIF value; whether Dubai Industrial City lies inside the customs territory could not be established from published sources; and a National Industrial Licence holder may claim exemption from duty on plant and raw materials regardless of the district’s status. Mainland activity is permitted by Executive Council Resolution No. (11) of 2025 of 3 March 2025 through three routes, of which article 12 of the Resolution prices only two — AED 10,000 a year for a licence for a branch located in the free zone and operating outside it, and AED 5,000 for a temporary permit — while a mainland branch is charged at the Department of Economy and Tourism’s ordinary tariff, and the one-year transition under article 13 expired on or about 3 March 2026, with separate books mandatory and the mainland permanent establishment’s profit taxed at 9 per cent. An industrial licence and registration in the federal Industrial Registry are mandatory for free zone establishments too, by article 3(1) of Federal Decree-Law No. 25 of 2022, in force from 2 January 2023. The district agrees its lease terms individually; what is officially confirmed is up to 4 megawatts per plot against 800 megawatts of total available capacity, a 105-kilometre road network with a 10-kilometre spine road, warehouses of 5,000 to 11,000 square feet, more than 56,000 worker beds and an Etihad Rail freight terminal on site.

If you are selecting a site for an industrial project in the UAE, or testing an existing structure against the Qualifying Free Zone Person conditions, the UPPERSETUP team can take you through the whole route — from written confirmation of the district’s status and customs perimeter to registration, the industrial licence and the annual reporting cycle: company formation and support in the UAE.

Sources

Dubai legislation

1.        Law No. (15) of 2014 Concerning Creative Clusters in the Emirate of Dubai — Dubai legislation portal

2.        Law No. (8) of 2023 Amending Law No. (15) of 2014 Concerning the Dubai Development Authority — article 3 and the schedule of land plots

3.        Law No. (8) of 2023 — full text in PDF

4.        Law No. (10) of 2018 Changing Names Related to the Dubai Creative Clusters Authority

5.        Law No. (1) of 2000 Of Dubai Technology, Electronic Commerce & Media Free Zone — repealed by Law No. 15 of 2014

6.        Decree No. (30) of 2017 Extending the Application of the Dubai Creative Clusters Urban Planning and Construction Legislation to Certain Land Plots

7.        Executive Council Resolution No. (11) of 2025 Regulating the Conduct of Free Zone Establishments’ Activities within the Emirate of Dubai

Dubai Development Authority

8.        DDA — the TECOM Group page listing the districts and stating the jurisdiction

9.        DDA — the free zone section

10.    DDA — Decision No. 1 of 2021 Concerning Licence Categories for Dubai Internet City, Dubai Media City, Dubai Knowledge Park, Dubai International Academic City, Dubai Outsource City, Dubai Production City, Dubai Studio City, Dubai Science Park, Dubai Design District and Emirates Towers (PDF)

11.    DDA — Dubai Creative Clusters Private Companies Regulations 2016 (PDF)

12.    DDA — the legal database of laws and regulations in force

13.    DDA — the archive of repealed instruments

14.    DDA — the register of circulars and announcements

15.    DDA — entity forms and how to set up a business

16.    DDA — FZ-LLC registration fees

Dubai Industrial City and TECOM Group

17.    Dubai Industrial City — official website

18.    Dubai Industrial City — About Us

19.    Dubai Industrial City — industrial land

20.    Dubai Industrial City — warehouses, specification and permitted use

21.    Dubai Industrial City — workers’ accommodation

22.    Dubai Industrial City — showrooms

23.    Dubai Industrial City — completion of a major expansion, 25 November 2020: 127 km of roads and more than 56,000 beds

24.    Dubai Industrial City — the 13.9 million sq ft expansion, 28 May 2024

25.    TECOM Group — twenty years of Dubai Industrial City, 21 November 2024: the six clusters and more than 1,100 customers

26.    TECOM Group — Dubai Industrial City attracts more than AED 1.7 billion of investment in twelve months

27.    TECOM Group — record revenue of AED 2.9 billion for 2025

28.    TECOM Group — commencement of trading on the Dubai Financial Market, 5 July 2022

29.    TECOM Group — Integrated Report 2025 (PDF)

30.    Government of Dubai — TECOM Group intention to float, 9 June 2022: the Manufacturing Cluster and 185 million sq ft

31.    Government of Dubai — Dubai Industrial City 2023 results, 19 February 2024: the 23.5 million sq ft F&B cluster

VAT

32.    Federal Tax Authority — the Designated Zones list as at 21 September 2021 (PDF)

33.    Federal Decree-Law No. 8 of 2017 on VAT and its amendments — Ministry of Finance consolidation (PDF)

34.    Federal Decree-Law No. 8 of 2017 and amendments — Federal Tax Authority publication of 28 November 2025 (PDF)

35.    Cabinet Decision No. 52 of 2017 — the VAT Executive Regulation and its amendments, Ministry of Finance consolidation (PDF)

36.    Federal Tax Authority — VAT Guide | Designated Zones | VATGDZ1 (PDF)

37.    Ministry of Finance — implementing the VAT Law amendments from January 2026

38.    Federal Tax Authority — VAT legislation index

Corporate tax

39.    Federal Decree-Law No. 47 of 2022 and its amendments — Ministry of Finance consolidation, January 2026 version (PDF)

40.    Cabinet Decision No. 100 of 2023 on Determining Qualifying Income for the Qualifying Free Zone Person (PDF)

41.    Ministerial Decision No. 229 of 2025 Regarding Qualifying Activities and Excluded Activities (PDF)

42.    Cabinet Decision No. 55 of 2023 on Qualifying Income — repealed by article 10 of Cabinet Decision No. 100 of 2023 (PDF)

43.    Ministerial Decision No. 139 of 2023 — repealed by Ministerial Decision No. 265 of 2023 (PDF)

44.    Ministerial Decision No. 265 of 2023 — repealed by article 6 of Ministerial Decision No. 229 of 2025 (PDF)

45.    Cabinet Decision No. 116 of 2022 — the AED 375,000 threshold (PDF)

46.    Ministerial Decision No. 73 of 2023 on Small Business Relief (PDF)

47.    Ministerial Decision No. 131 of 2026 — extending Small Business Relief to tax periods ending on or before 31 December 2029 (PDF)

48.    Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises (PDF)

49.    Ministerial Decision No. 96 of 2026 — Commentary and Agreed Administrative Guidance for Cabinet Decision No. 142 of 2024 (PDF)

50.    Ministry of Finance — UAE Domestic Minimum Top-up Tax

51.    Federal Tax Authority — Corporate Tax Guide | Free Zone Persons | CTGFZP1, May 2024 (PDF)

52.    Federal Tax Authority — Basic Tax Information Bulletin: Free Zone Persons (PDF)

53.    FTA Decision No. 3 of 2024 — corporate tax registration timelines (PDF)

54.    Cabinet Decision No. 75 of 2023 and its amendments — administrative penalties, including AED 10,000 for late registration (PDF)

Customs

55.    UAE Government portal — clearing customs and paying duty: 5 per cent of value plus CIF

56.    UAE Government portal — running a business in a free zone and the customs principle

57.    Federal Authority for Identity, Citizenship, Customs and Port Security — the GCC customs union

58.    Dubai Customs — Customer Guide Booklet, including the National Industrial Licence exemption (PDF)

59.    Dubai Customs — Service Guide 2025, version 9 (PDF)

60.    Dubai Customs — list of customs centres

61.    Dubai Customs — the Request Customs Duty Exemption e-service

Industrial regulation and strategies

62.    Federal Decree-Law No. (25) of 2022 Regarding the Regulation and Development of the Industry — act card

63.    Federal Decree-Law No. (25) of 2022 — full text

64.    Ministry of Industry and Advanced Technology — the Industrial Registry

65.    Ministry of Industry and Advanced Technology — the National In-Country Value programme

66.    UAE Government portal — the industrial strategy and Operation 300bn

67.    UAE Government portal — Dubai Industrial Strategy 2030

68.    UAE Government portal — Dubai Economic Agenda D33

69.    Government of Dubai — launch of Dubai Economic Agenda D33, 4 January 2023

Other federal obligations

70.    Cabinet Decision No. 109 of 2023 on Regulating the Real Beneficiary Procedures — full text

71.    Federal Decree-Law No. (10) of 2025 on anti-money laundering — act card

72.    Cabinet Resolution No. (134) of 2025 — its executive regulation

73.    Ministry of Finance — amendment to the economic substance requirements

Comparable zones

74.    Jebel Ali Free Zone — location and the 57 km² area

75.    Dubai Industrial City — About Us page: 105 km of road network, a 10 km spine road, 800 MW of available capacity

76.    TECOM Group — acquisition of 138 plots totalling 33 million sq ft in Dubai Industrial City for AED 1.6 billion, 28 August 2025

77.    Dubai Customs — list of customs centres, including the combined Jebel Ali & TECOM Customs Center entry

78.    The UAE’s policy on customs exemption for industrial production line inputs, 11 November 2022 — MoIAT competence, factory quota, on-site inspection

79.    Ministry of Industry and Advanced Technology — Request Customs Duty Exemption for Industrial Inputs service

80.    Federal Tax Authority — waiver of the late corporate tax registration penalty, 7 May 2025

81.    Dubai Development Authority — public register of circulars and announcements, including Circular 670 of 3 June 2026

A note on sources and levels of confirmation. The texts of Law No. 15 of 2014, Law No. 8 of 2023 with its attached schedule of plots, Law No. 10 of 2018, Decree No. 30 of 2017 and Executive Council Resolution No. 11 of 2025 were read directly on the Dubai legislation portal. The full title and article 15 of Decision No. 1 of 2021, and Regulation 25.1 of the Private Companies Regulations 2016, were read from the documents on the DDA’s own site. The Designated Zone list and its Dubai entries were read from the Federal Tax Authority’s published document. Article 2 and articles 3, 5, 6 and 7 of Ministerial Decision No. 229 of 2025, and articles 3, 5 and 8 of Cabinet Decision No. 100 of 2023, were read from the Ministry of Finance consolidations. JAFZA’s 57 km² area was read on the zone operator’s own site. Articles 5, 6, 7, 12, 13 and 15 of Executive Council Resolution No. (11) of 2025; article 51(1) of the VAT Executive Regulation in its consolidated text; articles 50 and 54 bis of the VAT Law in its consolidated text; article 3 of Federal Tax Authority Decision No. 3 of 2024; the definition of “Free Zone” in the consolidated text of Federal Decree-Law No. 47 of 2022; article 15 of DDA Decision No. 1 of 2021; the Dubai Customs list of customs centres; the Dubai Industrial City About Us page; the TECOM Group press release of 28 August 2025; the DDA register of circulars; and the Federal Tax Authority announcement of 7 May 2025 on the penalty waiver were all read directly in preparing this revision. Example 20 in section 6.1 of the Corporate Tax Guide | Free Zone Persons | CTGFZP1 is reproduced in full, including the second paragraph that industry summaries routinely omit.

What could not be confirmed, and is therefore not asserted here. No published Dubai instrument names Dubai Industrial City as a free zone; the plans demarcating the plot boundaries under Law No. 8 of 2023 are not attached to the published text, and whether the district’s customer plots fall inside the free zone perimeter cannot be established from open sources. The Cabinet decision listing Free Zones for corporate tax purposes, to which the Federal Tax Authority’s guide and bulletin both refer, is published on neither tax.gov.ae nor mof.gov.ae. Whether Dubai Industrial City lies inside the customs territory could not be established: the district is absent from Dubai Customs’ list of customs centres, and the 2025 Service Guide contains neither a customs definition of a free zone nor a list of customs free zones. Numeric distances from Dubai Industrial City to Jebel Ali Port and to Al Maktoum International Airport are not published by any official source and are not stated here. The list of economic activities required by article 9 of Executive Council Resolution No. 11 of 2025 could not be located at the time of writing, nor could any instrument implementing the Resolution. No Federal Tax Authority or Ministry of Finance guidance has been published on the interaction of mainland activity under Resolution No. 11 of 2025 with QFZP status, or on the application of the global top-up to a QFZP’s 0 per cent rate; the relevant conclusions are marked in the text as a reading of the instruments rather than as an official position. The full text of Cabinet Decision No. 98 of 2024 is closed to automated access, so the cancellation and refund of penalties for periods after 31 December 2022 is not confirmed here from a primary source. No record of an extension of the one-year transition under article 13 of Executive Council Resolution No. 11 of 2025 was found on dlp.dubai.gov.ae, so this analysis proceeds on the basis that the period has expired.

On non-primary sources. This analysis does not rely on publications by local consultancies and company-formation firms, property portals, or “top 10 UAE free zones” round-ups. Every measure of scale given here comes from an official publication of the district, TECOM Group or the Government of Dubai, with its source and date stated.

Disclaimer

This material is for information only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision you should obtain individual professional advice reflecting your specific circumstances, jurisdiction, company status and the regulators’ current requirements.

Material current as at: August 2026.