Dubai Maritime City in 2026: what it costs to set up a maritime company in Dubai, which licence Trakhees actually issues, and why this is not a free zone in the ordinary sense

Dubai Maritime City is, in the Dubai Government Media Office’s description, “a 249-hectare waterfront platform”, with 6,000-tonne and 3,000-tonne ship lifts, workshops, warehouses, office towers and residential blocks. It is a genuine industrial cluster with genuine numbers: design capacity of 1,000 vessels a year, a record 52 vessels on the dry berths on 28 July 2026, and 202 vessel calls in July 2026. Legally, however, Dubai Maritime City is neither a free zone created by its own statute nor a regulator in its own right. The law that created the “city” bearing that name was superseded on 6 February 2023 and nothing equivalent replaced it.

This review answers the practical questions: who exactly issues a licence here, what it costs on the official tariff, which two parallel licensing tracks run inside the same territory, what happens to corporate tax and VAT, where the boundary lies between the emirate and the federal ship registers, and which mistakes cost the most. Every conclusion is built on the operative texts of the laws, decrees and resolutions and on the published PCFC and Trakhees regulations, read in the primary source in September 2026.

Nine facts that change the picture

1.        Law No. (11) of 2007, which established Dubai Maritime City as a “city” with its own licensing authority, has been superseded in full by article 20(a) of Law No. (3) of 2023. The 2023 Law re-created neither the city, nor its licensing monopoly, nor the exemption from Dubai Municipality, the DED, the RTA and the DTCM.

2.        The only instrument in force that names Dubai Maritime City is Decree No. (22) of 2009 on Special Development Zones. Under it, DMC is a Special Development Zone, not a free zone.

3.        Licences here are issued by the PCFC through Trakhees, not by the maritime regulator. Article 2(2) of Decree 22/2009 gives the Corporation the exclusive right to issue “all types of licences” in Special Development Zones.

4.        Two parallel licensing tracks operate inside Dubai Maritime City — “Free Zone” and “Federal Law”. This is stated on Trakhees’ own form TRK-LD-LS-CF01k: row 8, Dubai Maritime City, carries “Yes” in both columns.

5.        Registration fees are fixed: FZCO AED 15,000, FZE AED 10,000, branch AED 5,000. Cancelling a licence costs AED 5,000 plus AED 1,500 for the notice.

6.        The AED 50,000 minimum share capital comes not from the regulations but from a Trakhees practice document. The 2018 Regulations themselves require only “sufficient” capital.

7.        Dubai Maritime City does not appear on the VAT Designated Zones list. The only “Maritime City” on that list is RAK Maritime City Free Zone in Ras Al Khaimah — a different emirate.

8.        A ship and a “watercraft” go on different registers. A ship acquires the UAE flag only on the register of the Ministry of Energy and Infrastructure; watercraft operating in the waters of the emirate are registered by the DMA.

9.        Dubai’s operative maritime penalty schedule runs to 116 items, not 31: the schedules to Resolution 11/2013 were replaced by Executive Council Resolution No. (9) of 2020.

What follows is the structure: the legal construction, the licences, the money, the tax, the vessels and the risks.

What Dubai Maritime City actually is: three different things under one name

In 2026 the term “Dubai Maritime City” covers three distinct entities, and most registration mistakes are born from conflating them.

First, a place. A 249-hectare waterfront platform on the emirate’s coast. The project’s own website names the operator as “Dubai Maritime City L.L.C.”; a Dubai Government Media Office release describes the site as a DP World GCC asset. The project’s own website divides the territory into two precincts: an industrial one (“ship lifts, warehouses, workshops and repairs, as well as supporting retail showrooms”) and a commercial one (“a mixed use area”) with retail, residential, office towers and a promenade.

Second, a former authority. The Dubai Maritime City Authority (DMCA), created by article 3(2) of Law No. (11) of 2007 “to manage the DMC”. That body was not dissolved — it was renamed. Article 3(b) of Law No. (3) of 2023 provides that the name “Dubai Maritime City Authority”, “wherever mentioned in any legislation in force in the Emirate, is hereby replaced by ‘Dubai Maritime Authority’”. The authority therefore outlived the law that created it but lost its tie to the place: today the Dubai Maritime Authority regulates the maritime sector across the whole emirate.

Third, a licensing jurisdiction. This is where the key lies. Neither Law 3/2023 nor any decree creates a free zone at Dubai Maritime City. The licensing regime of this territory flows from Decree No. (22) of 2009 on Special Development Zones, where Dubai Maritime City is expressly named in the definition of such zones alongside Nakheel, Limitless, Estithmar and the Dubai Multi Commodities Centre.

The practical consequence is simple and inconvenient for marketing copy: the phrase “Dubai Maritime City Free Zone” has no constituting instrument behind it. There is a territory, there is a Special Development Zone, there is the PCFC with an exclusive right to license, and there is a Trakhees regulation that calls the licences it issues “free zone licences”. That is not the same thing as a free zone created by a Ruler’s decree — and in the tax and customs sections the difference turns into money.

Law No. (11) of 2007: what it created and why it can no longer be cited

Law No. (11) of 2007 was issued in Dubai on 3 June 2007 (17 Jumada al-Ula 1428 A.H.). Article 16 provided for publication in the Official Gazette and entry into force on the day of issue — not on the day of publication; that detail distinguishes it from Law 3/2023 and from Decree 22/2009, both of which come into force on publication.

What the Law did:

•          Article 3(1) established “a city named the ‘Dubai Maritime City’, whose boundaries are demarcated on the plan attached to this Law”. The plan itself is not published on the Dubai legislation portal — the superseded act has no accessible cartographic component.

•          Article 3(2) established the Dubai Maritime City Authority, a body with legal personality, financial and administrative autonomy, affiliated to the PCFC.

•          Article 5 gave the authority power to issue regulations, grant licences, collect fees, own land and facilities, sell, lease and mortgage them, incorporate companies and enter partnerships.

•          Article 6 listed 22 licensable maritime activities — from ownership of ships and yachts through classification bodies, marine insurance, maritime financing, shipbuilding and repair, storage, marine equipment, maritime information systems and maritime conferences.

•          Article 11 allowed the authority to outsource management and operation of the territory to an “Operator” and to dispose of its assets up to and including transfer of ownership.

•          Article 12 removed the authority and the companies working on its land from the reach of Dubai Municipality, the Department of Economic Development, the Rent Committee, the DTCM and the RTA.

•          Article 13 created the monopoly: “No entity may conduct its activities within the DMC without first obtaining the required licence from the DMCA.”

It is articles 12 and 13 that produced what is colloquially called a “free zone regime”: a self-contained licensing perimeter and immunity from mainland regulators. Both are gone. Article 20(a) of Law No. (3) of 2023 says, in terms: “This Law supersedes the above-mentioned Law No. (11) of 2007” — supersedes it entirely, with no article preserved.

The only survival is in article 20(c), for subordinate instruments: “The regulations, resolutions, bylaws, circulars, and instructions issued in implementation of the above-mentioned Law No. (11) of 2007 will continue in force to the extent that they do not contradict this Law, until new superseding regulations … are issued.” That is a lifeline for the old maritime regulations, but it revives neither the city, nor the licensing monopoly, nor the fiscal immunity: those provisions sat in the Law itself, not in subordinate instruments.

Any 2026 write-up that describes Dubai Maritime City through the articles of Law 11/2007 is therefore describing a legal order that no longer exists. That Law may be cited only as the historical origin of the territory.

Law No. (3) of 2023: what replaced it, and why this is a regulator rather than a zone

Law No. (3) of 2023 Concerning the Dubai Maritime Authority was issued on 6 February 2023 (15 Rajab 1444 A.H.); article 21 brings it into force on the day of publication in the Official Gazette. It is an act about a regulator, not about a territory, and its architecture says so plainly.

Scope. Article 3(a): the Law applies to the Dubai Maritime City Authority, “established pursuant to the above-mentioned Law No. (11) of 2007 as a public authority”. The drafting is curious: the Law supersedes the 2007 act by article 20(a) yet defines the subject of its own regulation by reference to that superseded act. The body continues to exist as a historically constituted person, and its statute is now the 2023 Law.

Competence. Article 6: “The DMA is the competent entity in charge of regulating and overseeing the Maritime Sector and Maritime Activities in the Emirate, including in Special Development Zones and free zones, such as the Dubai International Financial Centre.” That is the exact inverse of the old model: instead of an authority for one site, a regulator for the whole emirate whose jurisdiction is deliberately extended into the zones.

What the Law does not contain. Across the 29 paragraphs of article 6 there is not a word about commercial trade licences. Paragraph 6(6) confers power to “issue all types of approvals and permits required for the work of the companies and corporations operating in the Maritime Sector … and for the conduct of Maritime Activities in the Emirate” — approvals and permits, that is sectoral clearances, not a trade licence. A company licence and a maritime permit are two different documents from two different bodies.

Definitions that matter commercially. Article 2 defines the “Maritime Sector” to include “the Ports, harbours, all types of public and private marinas, dry docks, Al Jaddaf, all types of islands, maritime logistic services and operations, Vessel building and maintenance facilities, maritime projects, and all establishments conducting Maritime Activities”. The “Waters of the Emirate” run from the Sharjah border to the Abu Dhabi border, including the exclusive economic zone and internal waters.

Powers and money. Article 11 shifts the authority’s funding onto the PCFC budget and PCFC-allocated property — under article 14 of Law 11/2007 the support came from the general budget of the emirate. Article 12(c) fixes the financial year at 1 January to 31 December. Article 16 gives the definition of violations and penalties to a resolution of the Chairman of the Executive Council — not the PCFC Chairman, as in 2007. Article 17 gives DMA employees the capacity of law enforcement officers, with power to inspect establishments and vessels. Article 18 allows the DMA to delegate any of its functions to a public or private entity by agreement.

The conclusion for a business is this: since 6 February 2023 the Dubai Maritime Authority is your sectoral regulator if you work with vessels, ports, marinas or maritime services. It does not issue your trade licence and it does not make your company a free zone resident.

Decree No. (22) of 2009: Special Development Zones and where Dubai Maritime City sits in them

A Special Development Zone is a category of Dubai law introduced by Decree No. (22) of 2009, issued on 31 May 2009 (7 Jumada al-Thaniyah 1430 A.H.) and in force on publication in the Official Gazette (article 6). The Decree is short — six articles — and it is the instrument that answers the question of the legal authority under which licences are issued in Dubai Maritime City at all. The Supreme Legislation Committee portal records it as In Force, published in Official Gazette No. 341, with no amendments registered; the text itself is available in Arabic and in the English translation on dlp.dubai.gov.ae.

The definition (article 1). “Special Development Zones: Land, compounds, and areas owned by the PCFZC or DW, owned by their affiliated entities and companies in the Emirate, located within their jurisdictions, or located within the areas determined by the PCFZC or determined by a legislation issued by the Ruler, including, without limitation, Nakheel, Limitless, Dubai Maritime City, Estithmar, and Dubai Multi Commodities Centre.”

Note the construction: the list is open (“including, without limitation”) and the criterion is ownership of the land by the PCFC or Dubai World, or location within their jurisdiction. Dubai Maritime City entered that list not as a free-standing zone but as one project inside the perimeter of the state corporations.

The powers (article 2). “The PCFZC will be exclusively responsible for the following in the Special Development Zones: 1. supervising the regulation of all matters related to the Infrastructure and provision of Public Utilities; 2. issuing all types of licences in Special Development Zones; and 3. determining, estimating, imposing, charging, and collecting Service Fees and other fees…”.

Subordinate rule-making (articles 3 and 4). The PCFC issues the service-fee rules in coordination with the Land Department and RERA. Regulations on infrastructure, licences and public utilities are issued by the Chairman of the Corporation — that is the legal basis on which the Trakhees regulations rest.

A detail almost nobody checks. The preamble to Decree 22/2009 recites “Law No. (4) of 2001 Concerning Free Zones”. That Law was repealed by Law No. (12) of 2018 (issued 19 September 2018, Official Gazette No. 439; the Supreme Legislation Committee portal records it as in force and publishes it in Arabic only). The act on which the decree’s preamble relies therefore no longer exists, while the decree itself continues to operate: a preamble is not an operative provision.

A control case that shows the difference. When Dubai genuinely creates a free zone, it looks different. Decree No. (52) of 2025 (issued 17 November 2025, Gazette No. 748) “Establishing a Free Zone in the Emirate of Dubai” establishes, by article 2, a zone on a specific land plot No. 71117180, Al Aweer First, whose boundaries and area are demarcated on an attached plan; article 3(a) lists the applicable legislation (Laws 1/1980, 2/1986 and 1/2002 and Decree 1/1985), and article 3(b) names JAFZA as the body exercising the powers. Three elements: a plot, an applicable law, a licensing authority.

No such decree exists for Dubai Maritime City. Neither the “Free Zone and Special Development Zone Affairs” category of the Supreme Legislation Committee portal nor dlp.dubai.gov.ae publishes any instrument establishing a free zone on the territory of Dubai Maritime City. There is only the line in the definition of Special Development Zones.

Who actually issues the licence: the PCFC and Trakhees

The chain of authority runs: the Ruler → Decree 22/2009 → the PCFC → the Chairman of the Corporation → the Trakhees regulations → a company licence.

The PCFC (Ports, Customs and Free Zone Corporation) was established by Law No. (1) of 2001. Article 3: a public corporation with legal personality and financial and administrative autonomy, “managed on commercial basis”. Article 4 affiliates the Customs Department, the Dubai Ports Authority and the Free Zone Authority, together with their subsidiaries, to the Corporation.

A terminological trap matters here. Article 2 of Law 1/2001 defines “Free Zone” in exactly one way: “Free Zone: The Jebel Ali Free Zone.” In the law that created the PCFC, the free zone is JAFZA and nothing else. Dubai Maritime City is not mentioned in that Law at all.

Trakhees is the Department of Planning and Development, the regulatory arm of the PCFC. The Corporation’s own page (last updated 1 January 2026) states: “Department of Planning and Development - Trakhees was established by Decree No.22 of His Highness Sheikh Mohammed Bin Rashid Al Maktoum … and the implementation of its business started in 2009”, and then: “The Decree stipulated that the services of ‘Trakhees’ shall include land, complexes and areas owned by Ports, Customs and Free Zone Corporation, Dubai World or entities and subsidiaries of any of them … and includes, but not limited to Nakheel, Limitless, Dubai Maritime City.”

A source defect worth knowing. The published text of Decree 22/2009 contains the words “Trakhees” and “Department of Planning and Development” precisely zero times. The Decree vests the powers in the Corporation and authorises the Chairman to issue regulations (article 4). The PCFC’s own assertion that Trakhees was “established by Decree No.22” finds no support in the text of that decree — it is an administrative construction resting on the article 4 delegation. This creates no practical consequence for a licensee, but in legal due diligence the formulation must be exact: Trakhees acts as a department of the PCFC exercising the Corporation’s powers.

What Trakhees does, in three streams. The Corporation’s page names three pillars: Buildings Regulation & Permits; Licensing & Services; and Environment, Health, Safety & Sustainability. For a company in Dubai Maritime City that means one and the same body issues the trade licence, approves any fit-out of the premises and issues the operational fitness certificate — and links all three processes together.

The Dubai Unified Licence. PCFC pages in 2026 carry a notice: “Your Dubai Unified License (DUL) is the official recognition of your business identity and authorisation to conduct economic activities in the Emirate of Dubai. It serves as the sole authoritative reference for operational, regulatory, and verification purposes and shall be read in conjunction with a valid and active trade license certificate. No economic activity may be conducted unless the DUL is issued and remains valid.” A Trakhees licensee is therefore embedded in the emirate-wide business identity system — and it is the DUL that is named as the condition for applying for the mainland permit discussed below.

Who signs. The 2018 free zone companies regulations were signed by Sultan Ahmed Bin Sulayem as Chairman of the PCFC. Since 13 February 2026 the Chairman of the PCFC, appointed by a decree of the Ruler, has been Abdulla bin Damithan, previously CEO and Managing Director of DP World UAE.

Two parallel licensing tracks inside one territory

This is the central practical finding of the review, and it is confirmed by Trakhees’ own document — form TRK-LD-LS-CF01k, Rev.01, July 2022, headed “Special Development Zones – Trakhees qualified/available for licensing” and marked “Classification: Public”. The form is a table of 33 projects, each marked in two “Legal Type of License” columns: “Free Zone” and “Federal Law”.

Row 8 — Dubai Maritime City: “Yes” and “Yes”.

Of the 33 projects, all 33 carry the “Federal Law” mark; only eleven also carry “Free Zone”: Port Rashid, Dry Port, Dubai Maritime City, Palm Jabal Ali, Palm Jumeirah, Palm Deira, The world Island, Dragon Mart, Nad Al Shiba Third, Fresh Market (Ras Al Kour) and Umm Suqaim First and Second — the spellings are reproduced as they stand on the form itself. The remaining 22 — including Hamriya Port, JAFZA North Free Zone and Jabal Ali Port, JAFZA South, Dry Dock, Jaddaf, Jumeirah Islands, Discovery Gardens and International City 1&3 — are available for “Federal Law” licences only.

What that means in practice.

The “Free Zone” track. The company is registered as an FZE, an FZCO or a branch under the Executive Regulations of the Free Zone Companies in the Special Development Zones. Ownership may be entirely foreign by the construction of the Regulations themselves. The licence, under regs. 9-6 and 10-6, “is valid for operation in the Special Development Zones and does not authorize” business outside them.

The “Federal Law” track. In the Trakhees service catalogue this is the “رخصة محلية” — the local licence, “issuing a local licence within the scope of the special development zones”, aimed at “companies and establishments licensed by Trakhees under the local law system of the Emirate of Dubai”. The company is governed by the federal Commercial Companies Law, not by the free zone regulations. The fee formula is different: a market fee of 5% of the premises lease, a housing fee of 5% of the accommodation lease of a non-national partner or manager, plus the fees of other government departments by activity.

Why this is critical. Choosing an address in Dubai Maritime City does not of itself make a company a free zone resident. The legal type of licence is chosen at application and determines everything downstream: the applicable corporate law, the ownership structure, the fee formula, the right to operate outside the zone and — most consequentially — whether the company can even be considered for Qualifying Free Zone Person status for corporate tax. The QFZP regime and its conditions are unpacked in Qualifying Free Zone Person in 2026, and the mainland-versus-zone comparison in Mainland versus free zone in 2026.

Entity forms under the Trakhees regulations: FZE, FZCO and two kinds of branch

The corporate statute of the “Free Zone” track is the Executive Regulations of the Free Zone Companies in the Special Development Zones for 2018, issued by Trakhees “in its capacity as the regulatory arm of Ports, Customs and Free Zone Corporation according to Decree No. (22) of 2009” (reg. 2).

Two dates that must be kept apart. The document’s title says “2018”, but the signature page reads: “Issued by us in Dubai on 1 April 2020”, signed by Sultan Ahmed Bin Sulayem, Chairman of the PCFC. Reg. 4 sets commencement: “These Regulations shall take effect one month after being published on the website of the Department of Planning & Development – TRAKHEES.” The publication date is not stated in the document, so the exact commencement date cannot be derived from the text. The “one month after website publication” rule is not a Trakhees invention but an application of article 5 of Dubai Law No. (15) of 2016 on the regulatory legislation issued by free zone and special development zone authorities: published legislation becomes binding 30 days after publication unless it says otherwise.

FZE — Free Zone Establishment. Under reg. 9-1 it is “a limited liability company with one shareholder”. It has separate legal personality (9-3) and the capacity of a natural person (9-4), and may not invite the public to subscribe for shares (9-5).

FZCO — Free Zone Company. Here the Regulations and the Trakhees practice document diverge. Reg. 10-1: “A FZCO is a limited liability company with a minimum of one (1) and a maximum of five (5) shareholders.” The document PCFC-TRK-LSD-CLS-REG-01, Rev.02, April 2023, “Legal Type of Free Zone Licenses”, says otherwise: “a minimum of two shareholders and maximum of five shareholders”, who may be individuals, non-individuals or a combination. Practice follows the 2023 document.

Branch and overseas branch. The Regulations (reg. 6-2) allow a foreign company to establish a branch. REG-01 distinguishes a Branch Licence from a Branch Overseas Licence: both are 100% owned by the mother company, operate under the same name and conduct the same business, appoint a branch manager, require no share capital, and attract a registration fee of AED 5,000; the difference is that for an overseas branch “the entire legal document must be notarized and attested by UAE embassy in the parent company and ministry of foreign affairs in UAE”.

Three defects in the regulations worth knowing.

•          Reg. 6-1 announces: “These Regulations include the following three types of companies”, and then lists two — (a) FZE and (b) FZCO. The 2023 practice document names four licence types.

•          Reg. 3, “Application of Laws”, states: “The Federal Commercial Companies Law No (2) of 2015 shall not apply to any free zone company or branches thereof save for any matter contained in these Executive Regulations.” Law 2/2015 was repealed by Federal Decree-Law No. 32 of 2021 — the cross-reference is stale.

•          The numbering slips: after reg. 7-3 it restarts, clauses “7-1” and “7-2” appear twice, the heading “8 — Registers” is followed by clauses numbered 7-3 to 7-7, reg. 43 contains a clause numbered “48-4” and reg. 44 a clause numbered “49-4”.

The choice between an FZE, an FZCO and a branch is made once and determines the cost of every later change; matching the form to a particular ownership structure and preparing the document pack is covered by the UPPERSETUP company registration service.

Share capital: the conflict between the regulations and practice

This is the case where two published documents of the same body say different things, and the difference is AED 50,000.

What the regulations say. Reg. 14 of the 2018 Executive Regulations reads, in full: “A FZE or FZCO shall have an amount of share capital that is sufficient for the activities permitted under the License.” No figure. It is a flexible formula tied to the content of the licence, not to a fixed threshold.

What practice says. Document PCFC-TRK-LSD-CLS-REG-01, Rev.02 of April 2023, provides for an FZCO: “The minimum share capital required is AED 50,000/-. Each share shall be of a value of AED 1,000/- or its multiples.” For an FZE the same AED 50,000 requirement appears, but with the wording “One share shall be of a value of AED 1,000/-”, which is internally inconsistent: capital of 50,000 divided into a single share of 1,000 does not add up.

How this plays out procedurally. The Regulations require shares to be paid in full on distribution unless the Registrar authorises a share to be partly paid (reg. 15-2). Reg. 11-3(c) adds that the Registrar issues a share certificate “at the request of customer provided that the capital has been deposited in full at the bank”. And in the document list for issuing a free zone licence the service catalogue expressly requires “a bank letter evidencing the deposit of the share capital”.

A UAE bank account has to be opened before the licence is issued, and for maritime companies this is usually the longest stage; account opening is supported by UPPERSETUP banking services.

The practical conclusion: budget on the basis of AED 50,000 actually paid into the company’s account, and plan in advance for the bank letter being required before the licence is issued, which means the account has to be opened first. The wording of reg. 14 may be an argument in negotiating a lower requirement for a narrow professional licence, but it cannot be relied on as the operative rule: Trakhees has published a later and more specific document.

Two further divergences in the same place.

•          The Regulations call an FZE “a limited liability company” (reg. 9-1); REG-01 calls it a “Limited Liability Partnership”. For practice this makes no difference: in both cases the construction is a separate legal person whose liability is limited to the capital contributed. But when translating documents the difference has to be seen.

•          The Regulations permit an FZCO with a single shareholder; the practice document requires two. If a transaction structure needs an FZCO with one owner, that has to be cleared with the Registrar in advance rather than discovered at filing.

What may not be done with shares. Reg. 15-4 prohibits bearer shares, reg. 15-5 prohibits fractional shares, and each share must carry a distinctive serial number (15-3). The bearer-share prohibition intersects with the federal beneficial-ownership requirements, unpacked further in Economic substance in the UAE in 2026.

What the licence costs: the official Trakhees tariff, step by step

The tariffs come from the “Service Catalogue for the Commercial Licensing Department” (دليل خدمات إدارة الترخيص التجاري), published by the PCFC across 124 pages. The document is issued in Arabic only and carries no revision date on its cover; the only years appearing anywhere in its text are 2015 (the creation of the customer relations section) and the standard ISO 10002:2014. It nonetheless remains a live PCFC publication as at September 2026, and its registration fees match the Trakhees document of April 2023, which corroborates them.

A rule the catalogue repeats throughout: “the payment permit printed from the electronic system is the authoritative one for paying the fees”, and for a number of services the amount is “calculated automatically by the system”. The figures below are therefore a budgeting guide; the amount actually payable is generated by the system at filing.

Step 1. Initial approval — AED 120. Service level: 5 working days. The pack: licence application form, FZ/FZCO registration form, trade name certificate, environment, health and safety form, copies of valid passports and residence pages for all shareholders, owners and managers, a no-objection letter from the sponsor or employer for non-nationals, a personal information form, signature specimens, and a board resolution (owners’ declaration).

Step 2. Trade name reservation — AED 220, plus surcharges for “special features” of the name: 1,000 for Arabised names, 2,000 for foreign words, 1,000 for a domain-indicative name, 1,000 for Firm Coverage (Global, International), 2,000 for abbreviations, 2,000 for a name containing “Dubai”, “UAE” or “Gulf”, 2,000 for a name containing numbers, 1,000 for a trademark or franchise name.

Step 3. Company registration. FZCO AED 15,000, FZE AED 10,000, branch AED 5,000. A mandatory condition: a valid lease registered with Ejari.

Step 4. Licence issuance. Here there is no fixed price but a formula. AED 20 is added to the final amount for Knowledge and Innovation. The standard activity count is 5 for a professional licence and 7 for a commercial one.

For projects outside Dragon Mart the licence fee is the sum of the following components:

The manager’s housing fee is not charged if the manager or partner produces the lease, the DEWA bill and evidence that the housing fee has been paid.

A worked example. A 100 sq m office at an annual rent of AED 120,000, a commercial licence, one manager housed in Dubai at AED 90,000 a year: market fee 9,000 (7.5% of 120,000) + housing 4,500 (5% of 90,000) + service improvement 500 + local 500 + printing 50 + signboard 350 + 20 = AED 14,920 for the first licence, on top of AED 15,000 FZCO registration, AED 220 for the name and AED 120 for initial approval. That is a starting government bill of roughly AED 30,260, before rent, visa costs and the bank deposit.

For comparative pricing in other UAE jurisdictions, the reviews of DMCC and Meydan Free Zone are useful.

Renewal: what changes in the bill in year two

Renewal of a free zone licence is calculated on the same formula as issuance, with three differences.

First, a workers’ housing fee appears. The renewal bill adds a fee by labour category: category A AED 1,000, category B AED 500, category C AED 300. That line does not exist on first issuance. For a ship-repair workshop with thirty category C workers it adds AED 9,000 to the annual bill, and it is the single most commonly omitted line in second-year budgets.

Second, one market-fee rate changes. On issuance the hotel fee for 3-star and 2-star properties is AED 400 per bed; on renewal the same document shows AED 500 per bed. That is a divergence inside one published catalogue; for a maritime business it is immaterial, but anyone planning a mixed-use asset in the commercial precinct of DMC should be aware of it.

Third, the “no observations” condition. The catalogue expressly includes among the renewal conditions “no observations on the licence”. In practice that means unresolved EHS findings, a lapsed operational fitness certificate or unpaid fines will block renewal.

The renewal bill, outside Dragon Mart, comprises: market fee — annual rent × 7.5%; manager’s or partner’s housing fee — 5% of the accommodation lease in Dubai, AED 1,000 outside Dubai, AED 1,000 on a shared lease; workers’ housing fee by category at 1,000 / 500 / 300; service agent fee of AED 700 for professional licences; service improvement fee of 1,000 / 300 / 500; local fee 500; licence printing 50; signboard 350; AED 500 for each additional activity; and the trade-name special-feature surcharges.

Late renewal. The table of violations attached to the 2018 Executive Regulations contains the item “Non-renewal of the license — AED 200 per month. A fraction of a month shall be deemed a full month.” The rate is modest, but it accrues automatically and takes no account of the reason for delay; part of a month counts as a whole one. Separately, the Trakhees circular list includes document 07-TKSLD22, “Initiative for Waive Late Renewal Fees Free Zone Licenses” — one-off amnesties on this item have been declared.

What is not licence renewal but lands on the same bill. The Operation Fitness Certificate is renewed annually: item 82 of “Operational Requirements for Trakhees” requires it to be obtained before operations start and adds that “every year prior to renewal of Trade License, Operation Fitness Certificate renewal from the EHS Department shall be necessitate”. In practice that means an EHS inspection has to be passed before the licence renewal is filed — and time has to be allowed for it.

Bookkeeping, preparing the accounts for audit and the tax calendar are best run as a single workflow — that is what UPPERSETUP accounting services cover. Mandatory audit of financial statements is a separate federal topic; the 2026 requirements and thresholds are unpacked in Corporate audit requirements in the UAE in 2026.

Licence amendments and changes of legal form: the full price list

Every amendment to a Trakhees free zone licence is charged separately, and almost every one carries three constant lines: licence printing at AED 50 and AED 20 for Knowledge and Innovation, plus — for changes touching the membership or the name — an advertisement fee of AED 1,520.

What to notice in that table. A change of legal form costs exactly what first registration in the new form costs — AED 10,000 or AED 15,000 on top of the administrative fees. That is the direct monetary consequence of the choice of form at the outset: the mistake is corrected not by re-papering but by paying the registration fee again.

Document packs. For a name change: a board resolution, the amendment form, the original licence, the original memorandum, the original share certificate and certificate of incorporation, an amendment to the constitutive contract on the name change, and the trade name certificate. For an activity change: a board resolution, the free zone licence change form, the original licence, the EHS activities form, third-party approval where required, and an amendment to the constitutive contract. For a location change: the original licence, the change form, a request letter, EHS approval, and a copy of the Ejari-attested lease. For a change of manager: a board resolution, the change form, the original licence, a passport copy of the new manager and a no-objection letter for non-nationals, the accommodation lease of the manager or owner and the electricity bill, a notarised amendment to the constitutive contract (branches excepted), and the manager’s personal information. For a capital increase: a board resolution, the change form, the original licence, the original share certificate, a bank letter confirming the company’s new capital, and an amendment to the constitutive contract.

Ancillary administrative services. Updating the lease data is free. Changing a signature specimen costs AED 520. A certified true copy costs AED 220. A visit to a customer outside the service centre costs AED 1,000 per person plus 20. The representative card for a free zone licence costs AED 220 each for issuance, renewal and reprinting. By contrast, on the “Federal Law” track the representative card costs AED 1,020.

It is worth remembering separately that moving a company between UAE jurisdictions is not a licence amendment but a redomiciliation procedure in its own right; its mechanics are set out in Redomiciliation within the UAE.

Closing the company: AED 5,000, twelve conditions and twenty working days

Cancelling a free zone licence is the most expensive administrative operation in the Trakhees tariff after registration itself.

Cost. The licence cancellation fee is AED 5,000, the advertisement fee AED 1,500 and licence printing AED 50. The service level is 20 working days.

Twelve numbered conditions without which the application is not accepted (the numbering is reproduced as it stands in the catalogue).

1.        All work permits are cancelled except the manager’s.

2.        A clearance letter is obtained from the Commercial Licensing Department and the Government Services Section.

3.        A liquidation letter is produced from an auditor registered in Dubai — the catalogue specifically notes “for free zones only”.

4.        All fees and charges are settled.

5.        A clearance letter from the Jebel Ali Free Zone is produced —

6.        for establishments transferred from the Jebel Ali Free Zone (the catalogue splits one condition across two numbered lines).

7.        The original licence is produced, or a copy if the licence has expired.

8.        The establishment card is cancelled.

9.        The original certificate of incorporation and share certificate, or copies, are produced.

10.    The bank account is closed.

11.    The lease registered in the company’s name is cancelled.

12.    A no-objection letter from the company to the cancellation is produced.

A separate note adds that the filing must be made by a duly authorised person.

Which of those creates a genuine problem. Point 3 — the requirement for a liquidation letter from an auditor registered specifically in Dubai. Point 9 — closing the bank account before the licence is cancelled, whereas the bank will generally require a live licence to process the final transactions. The sequence has to be agreed with the bank in advance. Point 1 keeps the manager’s visa alive to the end of the process, which means continuing costs for the establishment card and medical insurance.

The liquidation procedure under the regulations. The liquidation part of the 2018 Executive Regulations requires the liquidator to notify all creditors by registered mail and to publish the commencement of liquidation “in two local daily newspapers, one in Arabic and one in English, to invite objections to the liquidation within a minimum period of (45) days” (reg. 56-2). The order of distribution (reg. 56-3) is rigid and non-standard: “(a) First for settlement of the amounts payable to TRAKHEES; (b) The remaining for the settlement of the cost of liquidation, including the liquidator’s fee; (c) The balance shall be allocated to the creditors; and (d) The balance shall be distributed over the shareholders on a pro rata basis.” The regulator ranks ahead of the creditors and ahead of the liquidator.

Compulsory termination. Reg. 58-1 empowers the Registrar to terminate a licence entirely where the company: (a) fails to carry out the business set out in the licence within a year of incorporation, or its business under the licence has been suspended for a year; (b) violates Trakhees law or other applicable law; (c) fails to renew the licence; or (d) is ordered by a court to be liquidated. The first limb is a quiet trap for dormant structures registered “for the future”.

The Registrar’s sanctions. Reg. 59 (published on a page that exists only as an image) lists three heads of penalty: “(a) Termination of the License; (b) Imposition of a fine; or (c) Any other penalty determined by the Registrar.” Reg. 60 refers to the attached table of violations.

Premises, Ejari and why the licence is tied to square metres

A Trakhees licence is inseparable from the premises. Reg. 11-2 of the Executive Regulations expressly requires the incorporation application to be accompanied by “a draft memorandum and articles of association” and “a lease agreement”. Without a lease, registration does not start — this is not a recommendation but a mandatory item of the pack.

Ejari. The service catalogue requires a lease attested through Ejari, the Dubai Land Department system, with one carve-out on the “Federal Law” track: “a lease attested by (Ejari) the Real Estate Regulatory Agency”, with a carve-out for Nakheel contracts and those of the Dubai ports and customs entities, and the contract must have at least 30 days to run at the date of filing. The carve-out reflects the fact that leases inside port and corporate estates are papered differently.

What this means for a maritime business. The industrial precinct of Dubai Maritime City is workshops, sheds, warehouses and open yards beside the ship lifts. Leases there are granted by the site operator, Dubai Maritime City L.L.C., inside the DP World perimeter. Floor area feeds the licence bill directly: the market fee is 7.5% of the annual rent. Doubling the area doubles that line.

Changing location is a paid procedure. A change of address costs AED 500 in base fee plus AED 800 for EHS approval plus AED 50 for licence printing and AED 20 for Knowledge and Innovation, and requires EHS approval before filing. For an industrial facility that means a fresh assessment of whether the premises suit the declared activity.

The territorial limit of the licence. Regs. 9-6 and 10-6 put it identically for the FZE and the FZCO: “Such License is valid for operation in the Special Development Zones and does not authorize the FZE to carry out business outside the Special Development Zones. A FZE may operate in a jurisdiction other than the Special Development Zones subject to compliance with the laws of such jurisdiction.” In other words, the licence does not prohibit working outside — it simply does not authorise doing so on its strength; the mainland requires a separate instrument, discussed in the section on Resolution 11/2025.

Security over the premises. Reg. 49-1 allows several kinds of security to be created: a pledge of the company’s shares in favour of a bank or financial institution; a conditional assignment of the company’s lease in favour of any person; a mortgage over a building in favour of a bank or financial institution; a pledge over movable assets in favour of any person; and any other security available under UAE law as permitted by the Registrar. The key procedural rule is reg. 50-2: a security interest is created at the time it is entered in the Security Register maintained by the Registrar, subject to the consent of the Licensing Department. An agreement not entered in the register is not a security interest in this system.

The form of the security agreement. Reg. 49-2 requires the security agreement to be in the form approved by the Licensing Department Manager or his nominee. Reg. 50-3 requires security interests to be over existing assets or rights — future assets are not encumbered.

EHS: the operational fitness certificate and nine Trakhees maritime clearances

For the industrial precinct of Dubai Maritime City this is the most practically consequential section: it is where work stoppages and prohibition notices originate.

The base requirement. Item 82 of “Operational Requirements for Trakhees” (PCFC-TRK-LSD-CLS-REG02, Rev.01, March 2023): “Prior to start of Operations and storage at the facility, Operation Fitness Certificate from the EHS Department must be obtained. Every year prior to renewal of Trade License, Operation Fitness Certificate renewal from the EHS Department shall be necessitate.”

Specifically for ports and yards — item 69: “Ports/Marine/Shipyard/Wharfage/Jetty Operators shall obtain EHS Operation Fitness Certificate and ensure to renew/amended as applicable.”

Nine maritime procedures. Items 70 to 77 list individual clearances with their procedure codes:

Operating prohibitions that break conventional yard practice. Item 34: “Any kind of Operational Activities, Fabrication, Welding, Blasting, Painting, Carpentry etc., Installation of Machine/equipment, Racking and Material storage in the Open Yard outside the Factory/warehouse Building are NOT Permitted.” Item 35: blasting and painting in the open are prohibited — only in designated and approved chambers or booths. Item 36: washing and cleaning of equipment in the open yard without a proper washing bay fitted with waste-water recycling and collection is not permitted. Item 63: storage of fuel or diesel in loose cans and drums, and of LPG cylinders, is not permitted. Item 68: hot work, welding and cutting may not be carried out without a valid Permit To Work.

Equipment and testing. Item 61: lifting equipment, tools and tackle must hold a valid load test certificate from an EHS-approved third-party testing consultant, and lifting equipment and forklifts may be operated only by a licensed operator. Item 62: boilers, air receivers and pressure vessels require testing and certification by an EHS-approved third-party consultant. Item 42: the fire alarm system must be connected to the Dubai Civil Defence control room, extinguishers and alarms must be tested annually by a DCD-approved third party, and valid certificates must be furnished before licence renewal.

Chemicals. Item 78: storage and use of dangerous goods, fuel, diesel, lubricants and chemicals is not permitted without prior approval from the EHS Department. Item 79: to use and store chemicals at the facility the client must hold an EHS-approved chemical list.

A circular addressed to DMC by name. Circular EHS/PM/02/12 of 10 May 2012, still published on the PCFC site, is addressed “To: All companies operating in Dubai Maritime City (DMC) industrial precinct and other interested parties” and lists five mandatory approvals: EHS approval for lease and licence activities — mandatory for all clients; an EHS NOC for a building permit and the building permit itself from the Trakhees Civil Engineering Department for any modification or installation of machinery and racking; an EHS NOC for a building completion certificate and the certificate itself; EHS approvals for temporary portacabins and material storage; and operation fitness certificates — mandatory for all clients. Absence of valid certificates “shall be treated as serious violations to the regulatory requirements”, the cure period is 15 working days, and further delay “could result in imposition of appropriate action that may be in the form of financial penalty/Prohibition Notice”.

Trakhees fines: a table of 61 items

Attached to the 2018 Executive Regulations is a “Table of Penalties & Violations” — 61 rows covering everything from trading without a licence to dressing a shop front. For a company in Dubai Maritime City the following entries matter in practice.

Three conclusions from this table.

First: the largest fine — AED 20,000 — is not for trading without a licence but for submitting false information to the Corporation. That is the compliance benchmark: an inaccuracy on a form costs more than an expired licence.

Second: item 7, “practising a permitted business activity outside the establishment”, at AED 2,500, is a direct reflection of regs. 9-6 and 10-6 on the territorial reach of the licence. Operating from premises not named in the licence is a separate violation even where the activity itself is permitted.

Third: item 10, “obstructing the work of the Corporation’s employees”, at AED 10,000, is the most common cause of escalation at inspections. Combined with item 9 of “Operational Requirements”, which requires the owner and staff to co-operate with inspectors, it creates a duty to grant access rather than to debate the lawfulness of the visit on the spot.

An emirate-wide layer on top. On 13 March 2026 the Ruler of Dubai issued Law No. (6) of 2026 on violations, penalties and administrative measures in the Emirate of Dubai. According to the Supreme Legislation Committee, the Law classifies violations as minor, moderate or serious and allows a government entity to impose one or more administrative measures: a warning to correct the situation, temporary closure of the violating establishment for up to six months, permanent closure, cancellation or modification of licences, permits or approvals, and temporary or permanent suspension of all or part of the projects, activities or transactions directly related to the violation. Before publishing any administrative violation the competent authority must obtain the approval of its Director General and coordinate in advance with the Dubai Government Media Office. The Law takes effect from the date of its publication in the Official Gazette, and the Chairman of the Executive Council issues the implementing decisions. As at the date of this review the full text is not published on dlp.dubai.gov.ae, so individual offences and thresholds are not reproduced here.

Visas, the establishment card and the real headcount budget

Trakhees sponsors visas for the employees of companies licensed under the free zone system. The official tariffs from the service catalogue follow.

The establishment card. Issuance AED 480 on the standard track, amendment 260, renewal 480, reprint 260, cancellation 210. Without an establishment card no visa operations are possible.

An employee bank guarantee of AED 3,000 per member of staff. It is a refundable deposit, but it takes money out of circulation for the whole term of employment, and on a headcount of twenty it amounts to AED 60,000.

Issuing a work residence.

Category A covers the finance manager, administration manager, sales manager and similar posts; the catalogue requires an attested university degree to be filed with the application. That is a material detail for a maritime business, where technical managers often hold a maritime qualification rather than a university degree.

Renewing a residence. Three years with a health card AED 2,530, three years with insurance 2,470, one year 1,760. Service level 10 working days. The catalogue notes that immigration may issue a residence for one year or three under its own rules and the customer may not object to its decisions, while the company bears all fines caused by late filing. A defect in the catalogue text: the renewal condition is expressed as “the sponsored person must have 3 months remaining as a minimum or one month as a maximum” — internally contradictory wording, and the practical window has to be confirmed with Trakhees.

Other immigration fees. Cancelling a work permit inside the country AED 220. A work card for non-sponsored persons: issuance 860, amendment 260, renewal 520, reprint 220, cancellation 220. A medical test with a 48-hour result AED 120, a repeat test 280. Visa renewal 460. Health card renewal 420, replacement 120. Transferring a residence to a government entity 330, to another entity 530. An immigration status report 150. An absconding report AED 4,640, cancellation of an absconding report AED 1,640. A one-month visit visa 1,070, its cancellation 220. Increasing the company’s staff quota is free.

The establishment card, quotas and residences for crews and production staff are handled by UPPERSETUP visa services, and employment contracts, HR records and insurance by UPPERSETUP HR services.

How to budget. For a workshop with twenty category C workers recruited from abroad on three-year residences with health cards: 20 × 2,670 = AED 53,400 in visa fees, 20 × 3,000 = AED 60,000 in bank guarantees, 20 × 120 = AED 2,400 in medical tests, plus AED 480 for the establishment card. That is roughly AED 116,280 of start-up headcount cost, before salaries, insurance and the workers’ housing fee that appears at licence renewal.

The federal layer — employment law, onboarding paperwork and mandatory insurance — is regulated separately; a practical hiring checklist is set out in How to hire your first employee in the UAE.

Corporate tax: why QFZP status for a DMC company is an open question

This is the most expensive point in the whole construction, and it is also the one place where the honest answer is “not established”.

The definition everything starts from. Article 1 of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, in the Ministry of Finance consolidated text of January 2026, defines a Free Zone as “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”. The same article defines a Free Zone Person as “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”. Qualifying Free Zone Person status is available only to such a person.

The problem. No such Cabinet decision has been published. No official source contains a list of free zones for corporate tax purposes. The Federal Tax Authority’s own Free Zone Persons guide (CTGFZP1) repeats the statutory definition and then sends the taxpayer straight to the zone administration: “The list of Designated Zones for VAT purposes is provided by Cabinet Decision No. 59 of 2017. 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 guide names no zone at all. As at September 2026 the first edition of CTGFZP1, dated 20 May 2024, is still the current one, and it also cites the now-repealed Ministerial Decision No. 265 of 2023.

What this means for Dubai Maritime City specifically. The territory is not established as a free zone by a dedicated decree; it is named as a Special Development Zone in Decree 22/2009. Trakhees issues licences there which its own document calls “free zone licenses”. Neither of those is enough to assert that DMC is on a list that does not exist. The correct formulation for a tax file is therefore: free zone status for corporate tax purposes must be confirmed in writing by the licensing administration itself, and that confirmation should be obtained before the structure is decided.

If the status is confirmed — what follows. The ordinary construction then applies. Article 18(1) of Decree-Law 47/2022 requires a QFZP to maintain adequate substance in the State; derive Qualifying Income; not have elected into the ordinary regime under article 19; comply with articles 34 and 55 on the arm’s length principle and transfer pricing documentation; and meet any other conditions prescribed by the Minister. Article 3(2) meanwhile gives a QFZP its own two-rate scale: “0% (zero percent) on Qualifying Income” and “9% (nine percent) on Taxable Income that is not Qualifying Income under Article 18 of this Decree-Law”. That scale contains no nil band — the threshold below which the rate is zero sits in article 3(1) and does not extend to a QFZP.

The maritime specifics — and their hard boundary. Ministerial Decision No. 229 of 2025 (issued 28 August 2025, applying from 1 June 2023, repealing Ministerial Decision 265/2023) lists fourteen Qualifying Activities, and paragraph (e) of article 2(1) is “ownership, management and operation of Ships”. Moreover, article 2(2)(a) excludes transactions with natural persons from qualifying income, but paragraph (e) is expressly among the carve-outs from that exclusion — so selling ship ownership and operation services to a natural person does not become an Excluded Activity.

But paragraph (e) is narrowly defined, and that is the decisive detail. Article 2(3)(e) of the same decision provides: “Ownership, management and operation of Ships includes the ownership, management and operation of Ships used in the international transportation of passengers, goods or livestock, towing activities and the provision of general assistance to Ships at sea, dredging activities at sea, and leasing and chartering of Ships on a bareboat basis used in the international transportation of passengers, goods or livestock. This activity shall not include Ships used for local transportation or leisure or recreational purposes, or as floating hotels, restaurants or casinos.”

Several consequences follow that change the shape of a transaction. International liner and tramp shipping, marine towage, salvage assistance, dredging and bareboat chartering for international carriage are inside the list. The pleasure and charter fleet, yachting, excursion vessels, floating restaurants and hotels are outside it, expressly and by name. Intra-emirate and coastal carriage is outside it too. Ship repair, agency, broking and supply are not mentioned at all. For a substantial part of the tenants of the Dubai Maritime City industrial precinct this means income from mainland and overseas customers will be non-qualifying.

The de minimis threshold. Article 3 of Ministerial Decision 229/2025: non-qualifying revenue must not exceed 5% of total revenue or AED 5,000,000, whichever is lower. A breach costs the status from the beginning of the relevant tax period and for the four subsequent periods — five in a row.

The practical conclusion. For a maritime company in Dubai Maritime City the logic runs as follows: first obtain written confirmation from Trakhees whether the licence counts as a zone licence for corporate tax purposes; then check whether the principal activity falls within paragraph (e) or another qualifying category; and only then calculate de minimis. If any one of those three steps fails, the ordinary regime of 0% up to AED 375,000 and 9% above it — together with Small Business Relief for revenue up to AED 3,000,000, extended by Ministerial Decision No. 131 of 2026 to tax periods ending on or before 31 December 2029 — is both a better and a far more durable structure.

Drafting the request to Trakhees, testing the activity against the Ministerial Decision 229/2025 list and building a defensible tax position are covered by UPPERSETUP legal services. A full account of rates and regimes is in UAE corporate tax 2026, and the standard ways the zero rate is lost in How free zone companies lose 0% corporate tax.

VAT: Dubai Maritime City is not on the Designated Zones list — and the “RAK Maritime City” trap

Here the answer is unambiguous and can be verified in a minute.

What a Designated Zone is. It is a list of territories treated, for VAT purposes and subject to conditions, as outside the State for supplies of goods. The list was made by Cabinet Decision No. 59 of 2017 (effective 1 January 2018) and has been amended five times: by Cabinet Decisions No. 35 of 2018 (effective 18 June 2018), No. 43 of 2019 (4 July 2019), No. 34 of 2021 (4 April 2021), No. 63 of 2021 (1 July 2021) and No. 81 of 2021 (12 September 2021). The Federal Tax Authority publishes a consolidated list, marking the English part as “an unofficial translation”.

The nine Dubai entries on that list:

Dubai Maritime City does not appear. The list runs to 27 entries across seven emirates, three of which have ceased, leaving 24 effective. The only line anywhere in the document containing the words “Maritime City” is RAK Maritime City Free Zone in Ras Al Khaimah, effective from 1 January 2018. That is a ready-made trap: searching the list by name returns a match that has nothing to do with Dubai.

Why it could not be otherwise. Article 51(1)(a) of the VAT Executive Regulation, cited from the consolidated text the Federal Tax Authority published on 18 September 2025, requires a Designated Zone to be “a specific fenced geographic area” with “security measures and Customs controls” monitoring the entry and exit of individuals and the movement of goods. The commercial precinct of Dubai Maritime City is mixed-use development with housing, office towers, retail and a promenade. Such a territory cannot satisfy a fenced-perimeter-with-customs-control requirement by its very design.

And even if it could, the status does not help services. Article 51(6) of the Executive Regulation is expressed directly: “The place of supply of any Services is considered to be inside the State if the place of supply is in the Designated Zone.” Designated Zone status operates on goods, not services; for ship repair, agency, broking, bunker intermediation and marine consultancy it delivers nothing. Article 51(8) separately treats water and any form of energy as supplied inside the State, and article 51(5) taxes goods consumed within a Designated Zone.

What this means in practice. A company in Dubai Maritime City operates on the ordinary VAT footing: a 5% rate, a mandatory registration threshold of AED 375,000 and a voluntary one of AED 187,500. Exports of services may be zero-rated where article 31 of the Executive Regulation is satisfied, but that is the general export rule, not a zonal relief. The base act is Federal Decree-Law No. 8 of 2017 as amended by Decree-Laws No. 18 of 2022, No. 16 of 2024 and No. 16 of 2025, the last of which applies from 1 January 2026.

A full practical account of the regime is in UAE VAT: the complete business guide, and a comparison with a zone that genuinely holds Designated Zone status in the JAFZA review.

Operating on the mainland: Executive Council Resolution No. (11) of 2025

Until March 2025 a company with a zone licence had two ways of working outside the zone: incorporate a separate mainland company, or operate in a grey area. Executive Council Resolution No. (11) of 2025, issued on 3 March 2025 (3 Ramadan 1446 A.H.) and in force on publication in the Official Gazette, created a third.

Definitions (article 1). “Free Zone: Any free zone established in the Emirate by or under the relevant legislation.” “Establishment: A Company or corporation licensed by the Licensing Authority to operate in the Free Zone.” “Licensing Authority: Any authority legally mandated to supervise a Free Zone and license the Establishments operating therein.”

Scope (article 2). The Resolution applies to Establishments wishing to conduct their activities outside free zones. Financial establishments licensed in the DIFC are excluded.

Three instruments (article 4). The Dubai Department of Economy and Tourism (DET) may authorise mainland activity by issuing: (1) a licence to establish a branch of the Establishment within the emirate; (2) a licence to establish a branch of the Establishment operating out of the free zone; or (3) a permit to the Establishment to conduct specific activities within the emirate. The licences under (1) and (2) are valid for one year, renewable for the same period.

Conditions (articles 5 and 6). An application to the DET on its prescribed forms; the prior approval of the Licensing Authority; the approvals of the government entities supervising the activity, where required; a valid zone licence; the branch located within the emirate; payment of the fees; and any other conditions prescribed by a resolution of the DET Director General. The branch has no separate legal personality and is not deemed independent of the parent company.

The temporary permit (article 7). Valid for not more than six months. An additional condition: the activity must be on the list contemplated by article 9.

Staff (article 8). The Establishment may engage “its existing workforce registered on the Free Zone portal” and continue to benefit from all the free zone employment privileges applicable to that workforce. This is an important provision: it removes the need to re-paper employee visas.

Fees (article 12). AED 10,000 a year for issuing or renewing a licence for a branch operating out of the free zone, and AED 5,000 for issuing or renewing a temporary permit.

Duties after issue (articles 3(b) and 10). Compliance with the federal and local legislation applicable to the activity and — critically — maintaining separate financial records for the activity outside the free zone, distinct from those kept for activity inside it. The legislation of the emirate, including its administrative penalties and measures, applies to the licensed mainland activity.

Transition (article 13). Establishments already operating outside their free zone on the date the Resolution took effect had one year to comply; the DET Director General may extend that period once for the same term.

What is actually live. On 8 October 2025 the Dubai Government Media Office announced the launch of the Free Zone Mainland Operating Permit: administered by the Dubai Business Licence Corporation within the DET together with the Dubai Free Zones Council, priced at AED 5,000 for six months and renewable at the same fee, applied for through the Invest in Dubai platform by holders of a Dubai Unified Licence, with the first phase covering non-regulated activities — technology, consultancy, design, professional services and trading.

What is not live. Article 9 required the DET, with the Licensing Authority, to issue the list of economic activities within not more than six months of the Resolution’s effective date. As at September 2026 that list is unpublished, and maritime activity plainly does not belong to the “non-regulated” first phase.

The open question for Dubai Maritime City. The Resolution defines a free zone by reference to “the relevant legislation” and nowhere mentions Special Development Zones. Formally, its application to a Trakhees licensee is not obvious. Practically, the gateway is the Dubai Unified Licence, which the PCFC’s own pages describe as mandatory: “No economic activity may be conducted unless the DUL is issued and remains valid.” The correct sequence is a written request to Trakhees for the prior approval under article 5(a)(2) and a parallel check with the DET as to whether an application from a Special Development Zone licensee is accepted.

A tax effect that is often missed. Taking a mainland branch or permit creates a domestic permanent establishment. Article 5(1) of Cabinet Decision No. 100 of 2023 treats income attributable to a domestic or foreign permanent establishment as Taxable Income and taxes it under article 3(2)(b) of the Corporate Tax Law, that is at 9%; article 4(3)(b) of the same decision expressly excludes “Revenue attributable to a Domestic Permanent Establishment or a Foreign Permanent Establishment” from the calculation of both non-qualifying revenue and total revenue. Formalising the move onto the mainland therefore protects QFZP status, while unformalised mainland activity destroys it. More on this in Mainland versus free zone in 2026.

The federal layer: the new UAE Maritime Law and the State flag

Sooner or later a company in Dubai Maritime City runs into the question of where to register a vessel. The answer is split between two levels, and the boundary is drawn by federal law.

The operative act. Federal Decree-Law No. (43) of 2023 Concerning the Maritime Law: issued 28 September 2023, published in Official Gazette No. 760 of 29 September 2023, in force 29 March 2024 — article 369 sets the period at six months from publication. Article 368(1) repeals Federal Law No. (26) of 1981 on Maritime Commercial Law, as amended. Any citation of the 1981 law as being in force today is wrong.

Two key definitions in article 1. “The Ministry: Ministry of Energy and Infrastructure.” “The Competent Authority: The government of any of the Emirates or any other entity affiliated therewith.” It is through the second definition that the Dubai Maritime Authority fits into the federal architecture.

A ship and a watercraft are different objects. “The Ship: Any seagoing watercraft operating, or intended to be operated for maritime navigational purposes, even if it does not aim to make a profit.” “The Watercraft: Any seagoing or marine craft operating or intended to be operated in the territorial waters and water streams in the Emirate, whether for personal, commercial, sports or tourism purposes, and of whatever type or form.”

Where the flag is granted. Article 12(1): “The ship acquires the nationality of the State if it is registered in the Ministry’s Ships Register.” Article 14: ships registered in the Ships Register fly the State’s flag, and no other ships may fly it.

Registration conditions (article 13(1)).

1.        The ship shall normally be designated for navigation in the State’s maritime zones, coastal navigation between the State’s ports, or navigation on the high seas.

2.        The majority of the shares in the ship shall be owned by natural or legal persons holding the nationality of the State or of any Gulf Cooperation Council country, or by natural or legal persons having a domicile, headquarters or ship management office in the State.

3.        The ship shall be not more than 20 years old from completion of shipbuilding, except passenger ships, for which the limit is 10 years.

4.        Its drawings and specifications shall be approved by the Ministry or its authorised representative after inspecting the ship.

5.        It shall hold valid international certificates of fitness for maritime navigation issued by a classification body licensed by the Ministry, or whose certificates the Ministry approves.

Article 13(2) permits the Cabinet to amend those conditions, article 13(3) leaves the procedure to the Executive Regulations, and article 13(4) allows registration to be refused “in accordance with the requirements of the public interest”.

The second condition is the commercial logic of Dubai Maritime City. A ship-management company incorporated in the UAE with a ship management office here opens access to the UAE flag for ships in which it holds the majority of the shares.

Cabotage (article 15(1)). Foreign ships may not carry out maritime carriage between the State’s ports, or engage in fishing, towing, piloting, cruise, supply and fuelling or other maritime services and activities in the State’s maritime zones, without the approval of the Ministry on the conditions specified by the Executive Regulations.

The Register of Ships Being Built (article 9). A shipbuilding contract must be made in writing on pain of nullity; the Ministry maintains a special “Register of Ships Being Built” in which the contractor records the contract. For the yards of Dubai Maritime City this is a direct documentary requirement.

Defects in the English text on the legislation portal, worth knowing when citing: article 4 appears without a number — its text sits under the heading “Empty heading”; in the penal chapter, article 364 is followed by an article numbered “265” instead of 365; and in article 18, sub-paragraph (1)(a) requires the chartered ship “not be a bareboat”, while sub-paragraph (2) speaks of the mechanism for registering a chartered bareboat.

The emirate layer: the DMA register and Law No. (11) of 2010

The second half of the registration answer is the emirate’s.

The provision that joins the levels. Article 16(1) of Federal Decree-Law 43/2023: “No natural or legal person may practice any maritime activity through a seagoing watercraft unless the said watercraft is registered in the Register with either the Ministry or the competent authority.” Article 16(2) obliges the competent authority to link and share with the Ministry all data on registered watercraft and any change to it. Article 22(2): a seagoing watercraft registered with the Ministry or the competent authority is prohibited from practising any maritime activity without a navigation licence issued by the Ministry or the competent authority, as the case may be. Articles 7(3) and 17(2) allow the Cabinet to entrust the register to a competent authority, which then substitutes for the Ministry.

The emirate act. Law No. (11) of 2010 Concerning the Licensing of Vessels in the Emirate of Dubai was issued on 7 June 2010 (24 Jumada al-Akhira 1431 A.H.); article 26 brings it into force on publication in the Official Gazette. Article 2 defines the “Authority” as the Dubai Maritime City Authority; since 6 February 2023 that reference reads as the Dubai Maritime Authority by operation of article 3(b) of Law 3/2023. It is a clean illustration of how the renaming mechanism works: the 2010 Law was never rewritten.

The Authority’s competence (article 4). Running technical tests of maritime vessels; licensing and registering vessels after verifying compliance with the approved technical specifications; licensing masters and crews; monitoring and technically inspecting all vessels operating in the emirate, including their masters and crews, for compliance with the standards, including security systems and environmental controls such as the maximum thermal and carbon emission rates permitted; specifying the technical requirements for vessels authorised to engage in various maritime activities; setting the standards and bylaws governing tests and inspections; managing, with the relevant government authorities, the anchorage and berthing facilities; and specifying, with the RTA and the relevant authorities, the main maritime transport networks, routes and areas where maritime activities are allowed.

Sanctions (article 19). “Without prejudice to any higher penalty stipulated by any other legislation, a person who commits any violation of this Law shall be subject to a fine of not less than one thousand dirhams (1,000 dhs) and not exceeding fifty thousand dirhams (50,000 dhs). The fine shall be doubled in case of recurrence of the same violation within one (1) year, but may not exceed one hundred thousand Dirhams (100,000 dhs).” In addition: seizure of the vessel, suspension of the licence for up to six months, revocation of the licence. Article 20 gives nominated employees the capacity of judicial officers. Article 22 transfers from the RTA all powers, data and records relating to the licensing of maritime vessels.

The subordinate instrument. The implementing bylaw of Law 11/2010 was issued by Executive Council Resolution No. (11) of 2013 and substantially amended by Executive Council Resolution No. (9) of 2020, issued on 15 February 2020 (21 Jumada al-Thaniyah 1441 A.H.) and in force on publication. Resolution 9/2020 superseded articles 1, 2, 3, 9, 12, 15, 23, 24, 29, 30, 33, 35 and 52 of Resolution 11/2013, substituted “Recreational Vessel” for “Pleasure Vessel” throughout, and — most importantly — replaced both schedules in full.

A practical warning about the source. The PCFC booklet “Licensing of Maritime Vessels in the Emirate of Dubai”, carrying a 2014 copyright of the Government of Dubai Legal Affairs Department, is still published on the Corporation’s site and contains the original schedules: 58 fee items and 31 violations. It cannot be used to calculate fees or fines — the operative schedules are the 2020 versions, with 89 and 116 items respectively.

Where the DMA physically sits. The Dubai Maritime Authority’s customer happiness centre is located in the “Dubai Maritime City area - DMC building ‘Ground Floor’”, open Monday to Thursday from 08:00 to 14:30 and Friday from 08:00 to 11:30; a second centre is in Al Shindagha at the Critical Infrastructure and Coastal Protection Authority building. It is the one link between the regulator and the territory that survived 2023: an address.

DMA fees: the operative schedule of 89 items

Schedule (1), “Vessel Related Fees”, as replaced by Executive Council Resolution No. (9) of 2020, contains 89 items. Those that shape a commercial operator’s budget follow.

Anchorage. The per-day charge for anchoring a merchant ship in the waters of the emirate: more than three and up to fifteen days, AED 200 a day; beyond fifteen days at a length of up to 100 metres, AED 500 a day; over 100 and up to 200 metres, AED 1,000 a day; over 200 and up to 300 metres, AED 1,500 a day; over 300 metres, AED 2,000 a day. Mooring a merchant ship in an area determined by the DMA for a period not exceeding one day costs AED 1,000. Per-operation authorisations: cleaning the submerged part of the hull AED 1,000; a diving inspection of a ship AED 500; loading and unloading heavy cargo AED 3,000; replacing hydrocarbons with inert gas on a gas tanker AED 15,000; and inspecting sensitive working areas on board for a Chemical Inspection Office certificate AED 300 a day.

A defect in the schedule worth knowing. Rows 23 and 24 of Schedule (1) carry word-for-word identical descriptions— “conducting a technical inspection of a Commercial Vessel whose tonnage is one hundred and fifty (150) or more but less than three hundred (300) Gross Tons” — with different amounts, AED 600 and AED 800. On the logic of the scale, and on the bands published on the DMA portal, the third line should relate to vessels of 300 to less than 500 gross tons. Until the schedule is corrected, the rate for that band has to be confirmed with the Authority.

Three different documents, often collapsed into one word. Article 1 of Resolution 11/2013 as amended in 2020 distinguishes three instruments: a Licence, the DMA document authorising a vessel to navigate the waters of the emirate; a Permit, issued to a master, seaman, pilot or any other person working on board or conducting maritime activities; and an Authorisation, the document allowing an establishment to conduct an activity. Translations routinely collapse the second and third into a single word, so correspondence with the Authority is safer when the English term is used.

How to read the gap between the schedule and the portal. On the DMA e-services portal the same items are shown AED 20 higher: a recreational vessel licence at AED 120 against the AED 100 in the schedule. The difference is the Knowledge and Innovation dirhams of AED 10 each, charged emirate-wide on top of the tariff. For budgeting, work from the schedule and add AED 20 per transaction.

Inspection fees on the portal. A pleasure craft under 12 metres AED 220, 12 to 24 metres 420, 24 metres and above 820; a water sports craft 120; a commercial craft under 150 GT 420, 150 to 300 GT 620, 300 to 500 GT 820. No band for 500 GT and above is published on the portal — for such vessels the route runs to the federal register. A VHF frequency permit costs AED 600, a safe manning certificate 220, an inspector’s travel within the emirate 520 and outside it 2,020, printing an original document 70 and delivery 70.

A discount almost nobody writes about. Article 45(b) of Resolution 11/2013 allows the Authority to grant individuals and public and private entities a discount of up to fifty per cent on the prescribed fees for licences, permits, authorisations, certificates and services, in accordance with the cases, criteria and requirements prescribed by the Department of Finance.

DMA fines: the operative schedule of 116 items

Schedule (2), “Violations and Fines”, as replaced by Resolution 9/2020, contains 116 items against 31 in the original 2013 version. Those relevant to a commercial operator follow.

The mechanics of enforcement. Article 46(b) of Resolution 11/2013: the fine is doubled on repetition of the same violation within one year of the previous one, provided it does not exceed AED 100,000. Article 46(c) adds measures to the fine: suspending, cancelling or refusing to renew the permits of crew members; suspending, cancelling or refusing to renew the vessel’s licence; impounding the vessel until the causes of impoundment are removed; and prohibiting use of the vessel until its defects are repaired. Article 46(d): an impounded vessel is moved to the place designated by the Authority by navigating, towing or lifting, and is not released to its owner until the causes are removed and all fees, fines, impoundment costs and other costs are paid; if the owner fails to redeem it within the grace period, the Authority may dispose of the vessel, including by sale at public auction.

Remedying a violation at the Authority’s hand. Article 47: in addition to imposing a penalty, the DMA may order the violator to remedy the violation within a period it determines; failing which, the Authority may remedy it itself and the violator bears all the costs incurred plus an administrative charge of twenty per cent of those costs.

Who writes the reports. Article 48: employees and inspectors nominated by a resolution of the Authority’s Executive Chairman in coordination with the Director General of the Government of Dubai Legal Affairs Department have the capacity of civil enforcement officers, may issue violation reports and may seek assistance from police personnel. Article 49: fees and fines are paid to the Public Treasury of the Government of Dubai.

Three observations for risk management. First: late renewal of a vessel licence attracts not a lump sum but AED 100 a month, and only where the delay exceeds two months — the first two months are free. Second: obstructing inspectors and operating without a DMA authorisation cost exactly the same, AED 5,000 each; refusing an inspector entry makes no economic sense. Third: cooking on board without authorisation (item 36) and serving shisha without approval (item 37) attract AED 5,000 each — for the charter and tourism fleet these are the most frequent causes of enforcement.

What physically exists at Dubai Maritime City in 2026

The legal construction is half the answer. The other half is the production capacity, because that is what people come here for.

The scale of the site. A 249-hectare waterfront platform. The split into industrial and commercial precincts is confirmed by the project’s own website: the industrial precinct is “active and consists of marine services primarily dealing with ship lifts, warehouses, workshops and repairs, as well as supporting retail showrooms”; the commercial precinct is described as “a mixed use area” with retail, residential, office towers and a promenade.

Ship lifting. In September 2024 annual vessel-handling capacity was doubled — from 400 to 1,000 vessels a year. The 6,000-tonne and 3,000-tonne ship lifts were upgraded. An engineering, procurement and construction agreement was signed for four sets of ship cradles for vessels of up to 6,000 tonnes and 140 metres long, expected to add roughly another 100 vessels a year. New substations and shore power for docked vessels were commissioned.

Utilisation. In 2024 the site docked 296 vessels with a 16% increase in dry berth occupancy. July 2026 set a record — 52 vessels on the dry berths at once on 28 July 2026; dry berth occupancy rose 22% year on year; monthly traffic reached 202 vessels against 188 in July 2025, a 7% increase. Demand grew for servicing offshore vessels of up to 150 metresand for yachts. More than 500 ship cradle units are being acquired, able to handle up to 60 small boats. Some 16,000 weekly vehicle movements have been digitised and AI-based safety systems deployed.

Office property. On 22 May 2026 Maritime Business Centre 2 (MBC-2) opened — an investment of AED 160 million, 125 office units of 40 to 980 sq m, 480 parking bays, and a wellness floor with a gym and recreational areas. 78% of the space was leased before opening, and the building was delivered in 20 months. The site operator’s contact address is given as the Maritime Business Center, 10th Floor.

Who runs it. The operator is Dubai Maritime City L.L.C.; industry releases describe the site as a DP World GCC asset, and DP World executives attended the MBC-2 opening. The Chief Operating Officer of Dubai Maritime City is Ahmed Al Hammadi.

What the project’s website does not contain. Not a word about free zone status, not a word about licensing, no total floor area and no rental tariffs. The operator’s site is a commercial shop window for leasable space, not a source of legal information. That fact is worth keeping in mind: legal questions go to Trakhees, not to the operator.

What this means for site selection. Dubai Maritime City is not an office free zone where a company is opened for the address and the zero rate. It is a working industrial platform with ship lifts, where value is created by physical presence: access to dry berths, cradles, shore power and workshops. If a business needs none of lifting, repair, supply or an office beside them, there are few economic reasons to choose DMC over a zone with confirmed Designated Zone status.

Three budget scenarios: what entry actually costs

The calculations below use the official Trakhees and DMA tariffs. Rent, salaries, insurance, audit and professional fees are excluded: they depend on the market, not on the tariff.

Scenario A. Maritime consultancy, a 60 sq m office, FZE, one manager.

Scenario B. Ship-repair workshop, an 800 sq m shed, FZCO, 20 workers.

Scenario C. Ship owning and management, a 120 sq m office, FZCO, a fleet of three commercial vessels.

Three warnings about these figures.

First: in all three scenarios the largest variable is rent, because the market fee is 7.5% of the annual rental. An 800 sq m shed produces a licence bill three times that of a 120 sq m office, all else being equal.

Second: the AED 50,000 of share capital is not a fee but money in the company’s account. It nonetheless has to be paid in before the licence is issued, and a bank letter is required for the share certificate.

Third: exit costs are calculated separately. Cancelling a licence costs AED 5,000 plus AED 1,500 for the notice plus AED 50 for printing, requires a liquidation letter from an auditor registered in Dubai, cancellation of all visas except the manager’s, closure of the bank account and termination of the lease, and takes 20 working days. Exit has to be planned at entry.

If you are comparing DMC with other UAE jurisdictions, the reviews of Dubai CommerCity and Abu Dhabi Airport Free Zone are useful.

A step-by-step algorithm: eighteen steps from idea to operating company

1.        Decide whether you actually need this site. If the business needs no ship lifting, repair, supply or physical proximity to them, compare DMC with zones whose Designated Zone status is confirmed on the Federal Tax Authority list.

2.        Choose the legal type of licence — “Free Zone” or “Federal Law”. That decision determines the applicable corporate law, the fee formula and the boundaries of activity. There is no way back without paying the registration fee again.

3.        Ask Trakhees for written confirmation of whether the licence being issued counts as a zone licence for corporate tax purposes. The Federal Tax Authority’s guide sends the taxpayer to the zone administration for exactly this confirmation.

4.        Choose the form: FZE, FZCO, branch or overseas branch. Remember the divergence: the regulations permit an FZCO with one shareholder, the Trakhees practice document requires at least two.

5.        Test the activity against the list of Qualifying Activities in Ministerial Decision 229/2025. Ownership, management and operation of ships are on the list; ship repair, agency and broking are not.

6.        Select premises and agree the lease. The lease is part of the mandatory pack under reg. 11-2, must be attested through Ejari and must have at least 30 days to run at the date of filing.

7.        Reserve the trade name for AED 220, having first checked whether the chosen name attracts “special feature” surcharges — up to AED 2,000 per item.

8.        Obtain initial approval for AED 120, filing the full pack: application and registration forms, name certificate, EHS form, passports and residences of all shareholders and managers, a no-objection letter from the sponsor for non-nationals, personal data, signature specimens and a board resolution. Service level: five working days.

9.        Open a bank account and pay in the share capital. A bank letter evidencing the deposit is required for the licence, and a share certificate only where the capital is paid in full.

10.    Pay the registration fee and collect the Trakhees-registered constitutional documents: AED 15,000 for an FZCO, 10,000 for an FZE, 5,000 for a branch.

11.    Obtain EHS approval for the lease and the licensed activities — under circular EHS/PM/02/12 it is mandatory for all clients of the DMC industrial precinct.

12.    Pay for and collect the licence on the formula: market fee at 7.5% of the annual rent, the manager’s housing fee, service agent and service improvement fees, local fee, printing, signboard and AED 20 for Knowledge and Innovation.

13.    Clear any fit-out works with the Trakhees Civil Engineering Department: an EHS NOC for the building permit, then the permit itself, then an NOC for the building completion certificate and the certificate itself.

14.    Obtain the EHS operation fitness certificate before operations start and schedule its annual renewal ahead of the trade licence renewal.

15.    Take out the establishment card for AED 480 and open the visa file; lodge bank guarantees of AED 3,000 for each employee.

16.    Obtain the DMA sectoral maritime authorisations where the activity requires them: the annual maritime activity authorisation at AED 5,000, vessel licences and inspections, masters’ and seamen’s permits, and specific authorisations for bunkering, towing, transhipment and events.

17.    Register with the Federal Tax Authority for corporate tax and, above the AED 375,000 threshold, for VAT; set up separate accounting if activity outside the zone is contemplated.

18.    If mainland activity is needed, apply to the DET under Resolution 11/2025, having obtained Trakhees’ prior approval: AED 10,000 a year for a branch licence or AED 5,000 for a six-month permit, with mandatory separate financial records.

Working through these eighteen steps without repeat filings and duplicated fees is what UPPERSETUP company registration support is for.

Service levels from the catalogue. Initial approval: 5 working days. Issuing a residence: up to 20 working days where issued inside the country. Renewing a residence: 10 working days. Cancelling a licence: 20 working days. The company registration service level is stated in the catalogue in working days without a figure — plan around the actual clearance of the pack.

A useful orientation on the general tax calendar and filing deadlines is in What changed in UAE tax legislation from 1 April 2026.

Thirteen typical mistakes and what they cost

Mistake 1. Treating Dubai Maritime City as a free zone established by statute. Law 11/2007 was superseded in full on 6 February 2023, and there is no decree establishing a free zone on this territory. Cost: a structure built on a status that does not exist, and a tax position that cannot be defended on audit. The direct cost of rebuilding the structure starts at AED 15,000 of re-registration plus administrative fees.

Mistake 2. Choosing the wrong legal type of licence at the outset. Converting an FZE into an FZCO costs AED 15,000, the reverse costs AED 10,000, plus AED 500 base fee, AED 1,520 advertisement, AED 50 printing and AED 20 for Knowledge and Innovation. Cost: up to AED 17,090 to correct a decision taken in five minutes at filing.

Mistake 3. Assuming a zone licence permits mainland work. Regs. 9-6 and 10-6 do not permit it, and item 7 of the table of fines — “practising a permitted business activity outside the establishment” — costs AED 2,500. Cost:AED 2,500 in fines plus, more seriously, the risk of an unformalised permanent establishment and loss of QFZP status for five consecutive tax periods.

Mistake 4. Relying on Designated Zone status that does not exist. Dubai Maritime City is absent from the Federal Tax Authority list; the only line containing “Maritime City” relates to Ras Al Khaimah. Cost: misclassification of supplies of goods, VAT assessed at 5%, and penalties under the tax sanctions regime.

Mistake 5. Failing to obtain the operation fitness certificate before work starts. Item 82 of “Operational Requirements” requires it before operations, and circular EHS/PM/02/12 expressly calls its absence a “serious violation”. Cost: a financial penalty or a Prohibition Notice — a stoppage on site until cured; and at renewal, a block under the “no observations” condition.

Mistake 6. Welding, blasting or painting in the open yard. Items 34 and 35 of “Operational Requirements” prohibit it outright: painting and blasting only in approved chambers. Cost: an EHS regulatory breach with a stoppage of works; for ship repair this is the most likely cause of downtime.

Mistake 7. Forgetting the workers’ housing fee at renewal. The fee appears only in year two: AED 1,000 per category A worker, 500 for category B, 300 for category C. Cost: with thirty category C workers, AED 9,000 of unplanned expenditure every year.

Mistake 8. Calculating DMA fees and fines from the 2014 booklet. The schedules to Resolution 11/2013 were replaced in full by Resolution 9/2020: 89 fee items instead of 58 and 116 violations instead of 31. Cost: budget errors by a multiple and a mis-assessed risk; for instance, an annual authorisation for an establishment to refuel merchant ships costs AED 75,000, not the figure in the old edition.

Mistake 9. Assuming a vessel automatically gets the UAE flag through Dubai registration. The flag comes only from the Ministry of Energy and Infrastructure’s Ships Register under article 12(1) of Federal Decree-Law 43/2023, and the article 13 conditions include an age limit of 20 years, or 10 for passenger ships. Cost: a failed acquisition of a vessel over the age limit and the need to find another flag.

Mistake 10. Ignoring the cabotage rule. Article 15(1) of Federal Decree-Law 43/2023 prohibits foreign ships from carrying between the State’s ports and from fishing, towing, piloting, cruise, supply and fuelling in the State’s maritime zones without the Ministry’s approval. Cost: on the emirate scale, AED 5,000 for conducting a maritime activity on a commercial basis without a DMA authorisation, plus impounding of the vessel until the causes are removed and possible sale at auction if it is not redeemed.

Mistake 11. Planning to close the company “when needed”. Cancellation requires a liquidation letter from an auditor registered specifically in Dubai, closure of the bank account, termination of the lease and cancellation of all visas except the manager’s, and takes 20 working days. Cost: AED 6,550 in government fees plus several months of maintaining the manager’s visa, establishment card and insurance — several thousand dirhams more.

Mistake 12. Giving inaccurate information on a form. Item 13 of the Trakhees table of fines — “submitting false information to the Corporation” — costs AED 20,000, the largest fine in the table. Item 31 of the DMA schedule, for the same thing, costs AED 5,000. Cost: up to AED 25,000 across two regimes at once, before any reputational consequence at later clearances.

Mistake 13. Treating any ship business as a Qualifying Activity. Paragraph (e) of article 2(1) of Ministerial Decision 229/2025 reads broadly — “ownership, management and operation of Ships” — but article 2(3)(e) narrows it to international transportation, towing, assistance to ships at sea, dredging and bareboat chartering for international carriage, and expressly excludes ships used for local transportation, leisure and recreation, and floating hotels, restaurants and casinos. Cost: the entire revenue of a charter or excursion fleet falls into the non-qualifying side, the de minimis threshold of 5% or AED 5,000,000 (whichever is lower) is breached almost immediately, and the status is lost for the current period and the four that follow.

On tax penalties and how they are challenged, see UAE tax penalties, voluntary disclosure and appeals.

Who Dubai Maritime City suits, and who it does not

It suits.

•          Ship repair and shipbuilding companies that need physical access to the 6,000-tonne and 3,000-tonne ship lifts, cradles for vessels up to 140 metres, dry berths and shore power. That is what no amount of money can reproduce in an office free zone.

•          International ship owning and ship management structures, because paragraph (e) of article 2(1) of Ministerial Decision 229/2025 treats ownership, management and operation of ships as a Qualifying Activity — but, under article 2(3)(e), only so far as international carriage, towage, assistance to ships at sea, dredging and bareboat chartering are concerned; and article 13(1)(b) of Federal Decree-Law 43/2023 opens access to the UAE flag for a company with a ship management office in the State.

•          Suppliers of marine equipment and stores working with vessels under repair here. Proximity to a customer at a dry berth is a working competitive advantage.

•          Companies servicing the offshore fleet and yachts. Demand for servicing offshore vessels of up to 150 metres and for pleasure craft is reported as growing at this site specifically — though yacht charter itself is not a Qualifying Activity, and its tax model has to be built separately.

•          Companies that need an office beside the production. MBC-2 offers units from 40 to 980 sq m, and 78% of the space was leased before opening — evidence of real demand rather than marketing.

It does not suit.

•          Companies that need Designated Zone status for goods operations. There is none here, and by the design of the territory there cannot be. For those purposes JAFZA, DAFZA, Dubai CommerCity and the other zones on the Federal Tax Authority list exist.

•          Structures seeking guaranteed zero corporate tax. Until the Cabinet’s list of free zones is published, no zone can guarantee the status, and for DMC the question is further complicated by the territory being defined as a Special Development Zone.

•          Purely office and service businesses with no maritime connection. You will pay a market fee of 7.5% of rent on an industrial waterfront and receive neither ship lifting nor a tax advantage in return.

•          Companies whose principal turnover is on the UAE mainland. Until the activity list under article 9 of Resolution 11/2025 is published, maritime activity on the mainland through a zone licence is not formalised, and unformalised work destroys the tax position.

•          Projects that want the simplest and cheapest possible registration. AED 15,000 of FZCO registration, AED 50,000 of capital in the account and a licence fee tied to rent make DMC more expensive to enter than zones built for small business.

What to do next. If your business belongs to the first group, the next step is not choosing a package but making two written requests: to Trakhees, on the legal type of licence and the status for corporate tax purposes; and to the site operator, on available space and lease terms. Only once those are answered does a budget calculation become meaningful.

The UPPERSETUP team supports company registration in UAE free zones and special development zones, prepares document packs, handles communication with Trakhees and the sectoral regulators, and builds the tax position around a specific operating model. An overview of every available UAE regime is collected on the UPPERSETUP UAE page. The reviews of neighbouring jurisdictions — DMCC, DIFC and RAKEZ — help compare the options before filing.

Questions and answers

Is Dubai Maritime City a free zone?

No — not in the sense in which JAFZA or Dubai CommerCity is a free zone. Law No. (11) of 2007, which established a “city” with its own licensing authority, was superseded by article 20(a) of Law No. (3) of 2023, and no decree establishing a free zone on this territory has been issued. The operative classification is a Special Development Zone under Decree No. (22) of 2009. Trakhees nonetheless issues licences here that its own documents call “free zone licenses”.

Who issues a company licence in Dubai Maritime City?

The Ports, Customs and Free Zone Corporation, through its regulatory arm Trakhees. The basis is article 2(2) of Decree No. (22) of 2009, which gives the Corporation the exclusive right to issue all types of licences in Special Development Zones. The Dubai Maritime Authority does not issue a company licence: under article 6(6) of Law 3/2023 it issues approvals and permits for maritime activity.

What does it cost to set up a company?

The registration fee is AED 15,000 for an FZCO, 10,000 for an FZE and 5,000 for a branch. Initial approval is AED 120 and the trade name AED 220. The licence fee is calculated on a formula whose core is a market fee of 7.5% of the annual rent. Share capital under the Trakhees practice document is AED 50,000 paid into the company’s account.

What is the minimum share capital?

Reg. 14 of the 2018 Executive Regulations requires only capital “sufficient for the activities permitted under the License”, with no figure. The Trakhees practice document PCFC-TRK-LSD-CLS-REG-01, Rev.02 of April 2023, sets AED 50,000 for an FZE and an FZCO, with a share nominal of AED 1,000. Budget for AED 50,000.

Does a DMC company give zero corporate tax?

Not automatically. Qualifying Free Zone Person status is available to a person registered in a Free Zone, and a Free Zone under article 1 of Federal Decree-Law No. 47 of 2022 is an area “specified in a decision issued by the Cabinet at the suggestion of the Minister”. No such decision has been published, and the Federal Tax Authority’s guide sends the taxpayer to the zone administration for confirmation. Obtain written confirmation from Trakhees before deciding the structure.

Is Dubai Maritime City on the VAT Designated Zones list?

No. The Federal Tax Authority list carries nine entries for the Emirate of Dubai, and Dubai Maritime City is not among them. The only line anywhere in the document containing “Maritime City” is RAK Maritime City Free Zone in Ras Al Khaimah.

Can a company work with UAE mainland customers?

On a zone licence, only through the instruments of Executive Council Resolution No. (11) of 2025: a licence for a branch within the emirate, a licence for a branch operating out of the zone (AED 10,000 a year) or a temporary permit of up to six months (AED 5,000). The prior approval of the licensing authority and separate financial records are required. The activity list under article 9 of the Resolution is unpublished as at September 2026.

Where should a vessel be registered — in Dubai or federally?

It depends on the object. The UAE flag comes only from the Ministry of Energy and Infrastructure’s Ships Register under article 12(1) of Federal Decree-Law No. 43 of 2023. Seagoing watercraft operated in the waters of the emirate are registered by the Dubai Maritime Authority as the competent authority under article 16(1) of the same law.

What are the age requirements for the UAE flag?

Article 13(1)(c) of Federal Decree-Law 43/2023: not more than 20 years from completion of shipbuilding, and for passenger ships not more than 10 years. The Cabinet may amend those conditions under article 13(2).

Is a UAE company needed to register a ship under the UAE flag?

Not necessarily a company, but a connection with the State is needed. Article 13(1)(b) allows three routes: the majority of shares owned by persons holding UAE nationality, or by persons holding the nationality of a GCC country, or by persons having a domicile, headquarters or ship management office in the State. That last route is the construction for which ship management companies open an office in Dubai.

Does yacht charter or an excursion fleet fall within the Qualifying Activity?

No. Article 2(3)(e) of Ministerial Decision No. 229 of 2025 expressly excludes from paragraph (e) “Ships used for local transportation or leisure or recreational purposes, or as floating hotels, restaurants or casinos”. What remains qualifying is international transportation of passengers, goods or livestock, towing and general assistance to ships at sea, dredging at sea, and bareboat chartering for international carriage.

What are the fines for operating without a DMA authorisation?

Item 108 of Schedule (2) as replaced by Resolution 9/2020: conducting any maritime activity on a commercial basis without the relevant DMA authorisation, AED 5,000. The fine is doubled on repetition of the same violation within a year, capped at AED 100,000; suspension or cancellation of the licence and impounding of the vessel may be added.

What is the operation fitness certificate and how often is it renewed?

The Operation Fitness Certificate is the EHS Department’s clearance to operate the facility. Under item 82 of “Operational Requirements for Trakhees” it must be obtained before operations start and renewed every year, before the trade licence is renewed. For port, yard, wharfage and jetty operators the requirement is repeated in item 69.

Can welding and painting be done in the open yard?

No. Item 34 prohibits any operational activity, fabrication, welding, blasting, painting and carpentry in the open yard outside the building; item 35 requires blasting and painting to be carried out only in approved chambers. Hot work is possible only under a Permit To Work (item 68).

How long does closing a company take?

Twenty working days on the service catalogue, once the full pack is filed. The pack includes a liquidation letter from an auditor registered in Dubai, cancellation of all visas except the manager’s, closure of the bank account and termination of the lease. The fees are AED 5,000 for cancellation, AED 1,500 for the notice and AED 50 for printing.

Conclusions

The legal construction. Dubai Maritime City is a Special Development Zone under Decree No. (22) of 2009, not a free zone established by a law or a decree. Law No. (11) of 2007, which created a “city” with its own licensing authority, immunity from mainland regulators and a licensing monopoly, was superseded in full on 6 February 2023. Law No. (3) of 2023 created a maritime regulator for the whole emirate and re-created none of the three elements of the old regime.

Who issues what. The company licence is issued by the PCFC through Trakhees under article 2(2) of Decree 22/2009. Maritime approvals and permits are issued by the Dubai Maritime Authority under article 6(6) of Law 3/2023. These are two different bodies, two different documents and two different sets of fines, applied in parallel.

Two tracks, not one. Trakhees’ own form TRK-LD-LS-CF01k confirms that both legal types of licence are available at Dubai Maritime City: “Free Zone” and “Federal Law”. The choice is made at filing and costs AED 10,000 to 15,000 to correct afterwards.

Money. Registration is AED 15,000 for an FZCO, 10,000 for an FZE and 5,000 for a branch. The Trakhees practice document requires AED 50,000 of share capital, while the regulations themselves require only “sufficient” capital. The licence fee is tied to rent through the 7.5% market fee. In year two the workers’ housing fee is added. Closing costs AED 6,550 in government fees and twenty working days.

Tax. Qualifying Free Zone Person status is not confirmed here and cannot be confirmed until the Cabinet publishes a list of free zones; the Federal Tax Authority expressly refers the taxpayer to the zone administration for that confirmation. There is no Designated Zone status for VAT — Dubai Maritime City is absent from the list, and the only “Maritime City” on it is in Ras Al Khaimah. There is one piece of good news in the tax section, and it comes with a boundary: paragraph (e) of article 2(1) of Ministerial Decision 229/2025 makes ownership, management and operation of ships a Qualifying Activity and carves it out of the prohibition on transactions with natural persons, but article 2(3)(e) narrows the paragraph to international carriage, towage, assistance to ships at sea, dredging and bareboat chartering, and expressly excludes ships used for local transportation, leisure and recreation, and floating hotels, restaurants and casinos.

Vessels. The UAE flag comes only from the federal register of the Ministry of Energy and Infrastructure, with an age limit of 20 years, and 10 for passenger ships. Seagoing watercraft in the waters of the emirate are registered by the DMA. The operative fees and fines are the schedules to Resolution 11/2013 as replaced by Resolution 9/2020: 89 and 116 items respectively; the 2014 booklet still posted on the PCFC site carries the superseded 58 and 31.

What is genuinely valuable here. A 249-hectare working industrial waterfront, 6,000-tonne and 3,000-tonne ship lifts, a design capacity of 1,000 vessels a year, a record 52 vessels on the dry berths in July 2026, and a new business centre of 125 office units leased 78% before opening. That is physical infrastructure, and it — not a tax status — is the real argument for Dubai Maritime City.

The decision rule. If your business needs ship lifting, repair, supply or an office beside them, DMC is justified. If you are looking for a tax construction, look for it where the zone’s status is confirmed by a document rather than by a name.

Summary

Dubai Maritime City is a Special Development Zone in the Emirate of Dubai, not a free zone established by a dedicated law or decree. The legal basis is Decree No. (22) of 2009 on Special Development Zones, whose article 1 names Dubai Maritime City expressly in the definition of such zones. Law No. (11) of 2007, which established Dubai Maritime City and the Dubai Maritime City Authority, was superseded by article 20(a) of Law No. (3) of 2023 Concerning the Dubai Maritime Authority with effect from 6 February 2023.

Company licences here are issued by the Ports, Customs and Free Zone Corporation through its Trakhees department under article 2(2) of Decree 22/2009. Two legal types of licence are available: “Free Zone” (the FZE, FZCO, branch and overseas branch forms) and “Federal Law”. Registration fees are AED 15,000 for an FZCO, AED 10,000 for an FZE and AED 5,000 for a branch. The minimum share capital under the Trakhees practice document PCFC-TRK-LSD-CLS-REG-01, Rev.02 of April 2023, is AED 50,000, whereas the 2018 Executive Regulations require only “sufficient” capital. The licence fee includes a market fee of 7.5% of the annual rent. Cancelling a licence costs AED 5,000 plus AED 1,500 for the notice and takes 20 working days.

Dubai Maritime City does not appear on the list of Designated Zones for VAT purposes made by Cabinet Decision No. 59 of 2017 and amended five times; the list carries nine entries for the Emirate of Dubai, and the only line containing “Maritime City” relates to RAK Maritime City Free Zone in Ras Al Khaimah. Qualifying Free Zone Person status for corporate tax is unconfirmed, because the list of free zones contemplated by article 1 of Federal Decree-Law No. 47 of 2022 has not been published by the Cabinet.

The emirate’s maritime regulator is the Dubai Maritime Authority, constituted by Law No. (3) of 2023; its competence under article 6 extends across the whole emirate, including Special Development Zones and free zones. A ship acquires the UAE flag only on the Ships Register of the Ministry of Energy and Infrastructure under article 12(1) of Federal Decree-Law No. 43 of 2023 Concerning the Maritime Law, in force since 29 March 2024; the maximum age is 20 years, and 10 years for passenger ships. Seagoing watercraft in the waters of the emirate are registered by the Dubai Maritime Authority as the competent authority under article 16(1) of the same law. The operative fees and fines are in Schedules (1) and (2) to Executive Council Resolution No. (11) of 2013 as replaced by Executive Council Resolution No. (9) of 2020: 89 fee items and 116 violations.

The site covers 249 hectares, is divided into industrial and commercial precincts, and is operated by Dubai Maritime City L.L.C. within the DP World perimeter. Design capacity is 1,000 vessels a year; the ship lifts are rated at 6,000 and 3,000 tonnes; July 2026 set a record of 52 vessels on the dry berths at once and 202 vessel calls in the month. On 22 May 2026 the Maritime Business Centre 2 opened, an AED 160 million building of 125 office units of 40 to 980 sq m.

Sources, method of verification and disclaimer

How this was prepared. Primary sources first, writing second. Every instrument was read in its published text: Dubai laws and decrees on the legislation portal dlp.dubai.gov.ae and on the Supreme Legislation Committee portal slc.dubai.gov.ae, federal acts on uaelegislation.gov.ae, tax instruments on the Ministry of Finance and Federal Tax Authority sites, and the regulations and tariffs in the PDFs published by the Ports, Customs and Free Zone Corporation itself. Fees and fines are taken from the operative versions of the schedules, not from consolidated booklets. Dates of issue and dates of entry into force are stated separately. Currency was checked as at September 2026.

The Dubai layer

•          Law No. (11) of 2007 Establishing the Dubai Maritime City (superseded)

•          Law No. (3) of 2023 Concerning the Dubai Maritime Authority

•          Decree No. (22) of 2009 Concerning Special Development Zones

•          Law No. (1) of 2001 Establishing the Ports, Customs, and Free Zone Corporation

•          Law No. (15) of 2016 Concerning the Regulatory Legislation Issued by Free Zone and Special Development Zone Authorities

•          Law No. (12) of 2018 Repealing Law No. (4) of 2001 Concerning Free Zones

•          Law No. (11) of 2010 Concerning the Licensing of Vessels in the Emirate of Dubai

•          Executive Council Resolution No. (11) of 2013 — the implementing bylaw of Law 11/2010

•          Executive Council Resolution No. (9) of 2020, which replaced the schedules

•          Executive Council Resolution No. (11) of 2025 on the activities of free zone establishments

•          Decree No. (52) of 2025 Establishing a Free Zone in the Emirate of Dubai

•          The Supreme Legislation Committee’s announcement of Law No. (6) of 2026

PCFC and Trakhees documents

•          The Department of Planning & Development – Trakhees page

•          Executive Regulations of the Free Zone Companies in the Special Development Zones for 2018

•          Service Catalogue for the Commercial Licensing Department

•          PCFC-TRK-LSD-CLS-REG-01 “Legal Type of Free Zone Licenses”, Rev.02, April 2023

•          PCFC-TRK-LSD-CLS-REG02 “Operational Requirements for Trakhees”, Rev.01, March 2023

•          TRK-LD-LS-CF01k “Special Development Zones – Trakhees qualified/available for licensing”, July 2022

•          Trakhees circular EHS/PM/02/12 of 10 May 2012 for clients of the DMC industrial precinct

•          The Dubai Maritime Authority service catalogue

•          The DMA “Issuing Marine Vessel License” service page with its tariffs

The federal layer

•          Federal Decree-Law No. (43) of 2023 Concerning the Maritime Law

•          Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, the Ministry of Finance consolidated text

•          Cabinet Decision No. 100 of 2023 on Determining Qualifying Income

•          Ministerial Decision No. 229 of 2025 Regarding Qualifying Activities and Excluded Activities

•          Ministerial Decision No. 84 of 2025 on Audited Financial Statements

•          The Federal Tax Authority list of Designated Zones for VAT purposes

•          The Federal Tax Authority Free Zone Persons corporate tax guide CTGFZP1

Official announcements and industry sources

•          Dubai Government Media Office on Dubai Maritime City’s capacity increase, 26 September 2024

•          Dubai Government Media Office on the launch of the Free Zone Mainland Operating Permit, 8 October 2025

•          Dubai Government Media Office on the appointment of the PCFC Chairman, 13 February 2026

•          Gulf Today on the opening of Maritime Business Centre 2, 22 May 2026

•          The Maritime Standard on the dry berth occupancy record, 1 September 2026

•          The site operator’s Dubai Maritime City website

Source defects recorded during verification. The published text of Decree 22/2009 does not mention Trakhees, although the PCFC attributes the department’s establishment to that decree. The 2018 Executive Regulations are titled “2018” but signed on 1 April 2020, announce “three types of companies” and list two, cite the repealed Federal Law No. 2 of 2015, and contain a break in clause numbering. Page 48 of those Regulations is published as an image with no text layer. The PCFC site sections “License Types of Free Zone” and “Special Development Zones” are published but empty. The Service Catalogue is issued in Arabic only and without a revision date; its residence renewal condition is internally contradictory. In Schedule (1) to Resolution 11/2013 as replaced by Resolution 9/2020, rows 23 and 24 carry word-for-word identical descriptions of a commercial vessel technical inspection with different amounts, AED 600 and AED 800. The Dubai Maritime Authority’s e-services portal still runs on the dmca.ae domain three years after the renaming and refers customers to “the DMCA website”. The PCFC booklet of 2014 carries the superseded schedules to Resolution 11/2013. In the English text of Federal Decree-Law 43/2023 on the legislation portal, article 4 appears without a number under the heading “Empty heading”, and in the penal chapter article 364 is followed by an article numbered 265. The Federal Tax Authority guide CTGFZP1 remains in its first edition of 20 May 2024 and cites the repealed Ministerial Decision No. 265 of 2023. The full text of Dubai Law No. (6) of 2026 is not published on dlp.dubai.gov.ae as at the date of this review.

Honest gaps. The exact commencement date of the 2018 Executive Regulations cannot be derived from their text: reg. 4 ties it to the date of website publication, which the document does not state. The Service Catalogue carries no revision date. The list of free zones for corporate tax purposes contemplated by article 1 of Federal Decree-Law 47/2022 has not been issued by the Cabinet. The list of economic activities that article 9 of Resolution 11/2025 required within six months is unpublished. Rental tariffs at Dubai Maritime City are not published by the operator. The total leasable area and the number of licensees on the site are not officially disclosed.

Disclaimer. This material is for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision, individual professional advice should be obtained that takes into account the specific situation, the jurisdiction, the status of the company and the current requirements of the regulators.

Updated: September 2026.