Aircraft Spare Parts Trading Company in the UAE (2026): The Licence, DCAA Permit, Form 1 Paperwork, Unapproved Parts, Export Controls and Tax

An aircraft spare parts trading company in the UAE sells a product whose value sits in its paperwork. The Dubai Civil Aviation Authority (DCAA) lists "Trading in Aircraft spare parts and components" as an activity that needs its own permit on top of the trade licence [1]. The 2017 fee schedule prices that permit at AED 6,500 a year and fines anyone trading without it AED 10,000 [2]. And a UAE airline or maintenance shop may fit your part only if it "has been appropriately released to service" on an AW Form 1 or an accepted equivalent [3].

So the licence is the quick part. What decides whether stock sells is the certificate in the box, the history behind a used part, the end user behind an export order and how each sale is taxed. Get those wrong and you hold inventory nobody can install, or a VAT bill on a sale you priced as zero-rated.

Since 2013, BusinessDubai.ae has helped founders set up trading companies across the UAE free zones and the mainland. This guide covers the activity codes, the DCAA permit, the release certificates (AW Form 1, EASA Form 1, FAA 8130-3), unapproved parts, accreditation, export controls, customs, VAT, corporate tax and first-year cost. It is general information, not legal or tax advice: confirm your position with the DCAA, the GCAA, the Federal Tax Authority and your adviser.

What does a UAE aircraft spare parts trading company need?

A UAE aircraft parts trader needs a trading licence (DAFZ 4773-708 or DET 4773708) and, in Dubai, a DCAA permit costing AED 6,500 a year under the 2017 schedule. No GCAA distributor approval was found, but buyers can only fit parts released on an AW Form 1 or an equivalent such as EASA Form 1 or FAA 8130-3.

Only the licence, from a free zone or the Dubai Department of Economy and Tourism (DET), and the yearly DCAA permit are issued to you. You build the rest: paperwork and quarantine, export screening and a tax position per type of sale. If you are still choosing a zone, the best free zones for aviation guide compares them; this article is about running the parts business.

What kinds of aircraft parts will you trade, and what does each need?

An aircraft parts trader usually handles six kinds of stock: new OEM parts, FAA PMA parts, overhauled or serviceable parts, used and salvaged parts, standard parts and consumables, and rotables on exchange. Each needs different paperwork before a UAE buyer can fit it, and used stock falls under a separate DCAA list item.

The table maps each stock type to the release document a buyer asks for under the GCAA's CAR-M and CAR-145 [3][4], its DCAA activity [1] and the usual VAT point.

Aircraft parts are not one product: a new-parts distributor and a teardown trader need different suppliers, records and DCAA permit lines.

Which licence and zone should an aircraft parts trader choose?

An aircraft parts trader can licence in a Dubai free zone, on the Dubai mainland or in another emirate. BusinessDubai.ae's Dubai South and Meydan Free Zone packages start at AED 12,500 without a visa; the Dubai mainland starts at AED 18,200. Every Dubai route needs the DCAA permit; whether a zone offers the activity must be confirmed with the zone.

The activity codes

Dubai Airport Free Zone (DAFZ) publishes two parts codes in its ISIC Activity List 2025 [5]:

• 4773-708 Aircraft Spare Parts & Components Trading: "This includes the trading aircraft spare parts and components, providing critical aviation solutions and maintenance support."
• 4669-109 Aircraft scrap and used spare parts trading: "This includes the trading aircraft scrap and used spare parts, serving the aviation industry's maintenance and repair needs."

The list warns that "The activity list is not final and is subject to change by DAFZ" and that "NOC will be required for certain activities" [5]. Other zones use their own wording, so ask each zone for its exact activity name.

For the mainland, the Dubai Department of Economy and Tourism business activity list, as recorded in a public copy of the register, carries 4773708 Aircraft Spare Parts & Components Trading and 4669109 Aircraft Scrap & Used Spare Parts Trading, described as "Includes reselling aircraft scrap and used spare parts obtained from dismantling and scraping old aircrafts." [6]. Add 5210010 Airport Equipment & Aircraft Spare Parts Storage Services if you store parts for third parties. 3315005 Aircraft Engine & Parts Repair & Overhaul is a different business needing its own CAR-145 approval [6].

Common Mistake: Licensing only the new-parts code and then buying a teardown lot. In Dubai, used and salvaged parts are a separate DCAA item (SN 1) from new parts (SN 21), and DAFZ gives them a separate code (4669-109) [1][5]. Adding one later means a licence amendment and a change to the DCAA permit: the fee schedule lists AED 2,500 per application to amend permit details, but confirm whether DCAA treats a new activity as an amendment or a new AED 6,500 permit [2]. If used stock is possible in year one, licence both from the start.

The routes side by side

The table compares the routes on what matters to a parts trader. Prices are BusinessDubai.ae's current packages [19]; the Designated Zone column follows the Federal Tax Authority's list [7].

These packages are company formation only. They do not include the DCAA permit, a warehouse, ASA-100 or AS9120 accreditation, or any export licence. Our guides to DAFZA, Dubai South, SAIF Zone and Abu Dhabi Airports Free Zone cover each zone, and the Designated Zone VAT guide explains the IFZA and Meydan position.

The real decision is where your customers and stock sit: the mainland sells directly to UAE airlines and maintenance shops, while a fenced Designated Zone suits stock held for re-export. Our free zone company setup and mainland company setup pages itemise both routes, including renewal.

How does the DCAA permit for aircraft parts trading work?

The DCAA permit for aircraft parts trading is issued under Administrative Resolution No. 20 of 2023 to holders of a valid commercial licence, including Dubai free zone licences. The DCAA decides within ten working days, the permit lasts one year, and the 2017 schedule sets AED 6,500 to issue or renew it.

Who needs it

Executive Council Resolution No. 4 of 2017 says "No Person may conduct any aviation-related activity in the Emirate without first obtaining the relevant permit from the DCAA." [2]. Resolution No. 20 of 2023, issued 7 June 2023, lists the activities. SN 21 is "Trading in Aircraft spare parts and components", described as "Resale of Aircraft spare parts, components, and other supplies used in Aircraft repair, maintenance, overhaul, and operational enhancement" [1]. SN 1 is "Trading in Aircraft salvageable parts and used spare parts". Neighbours are SN 15, aircraft dismantling, and SN 26, spare parts storage for third parties [1].

The resolution defines the Licensing Authority to include "the authorities supervising Special Development Zones and free zones" [1], so a DAFZA, Dubai South, Meydan or IFZA trader needs the permit too.

The four conditions

Resolution No. 20 of 2023 sets four conditions [1]:

1. "The Permit applicant must hold a valid commercial licence issued by the competent Licensing Authority in the Emirate."
2. The DCAA's technical conditions, which are "published on the DCAA official website", must be met.
3. Copies of GCAA approvals are needed "where the legislation in force in the Emirate requires obtaining these approvals to conduct the Activity."
4. The fees under Executive Council Resolution No. 4 of 2017 must be paid.

The DCAA website did not load when we checked, so we could not read its document checklist: confirm it with the DCAA before you apply.

Timing and validity

The DCAA decides "within ten (10) working days from the date of submission of the application" [1]. If it refuses, it gives reasons and you may reapply. The permit lasts one year and is renewable.

Fees and fines

The lines below are from Executive Council Resolution No. 4 of 2017, issued 30 January 2017 [2]. Resolution No. 20 of 2023 still points to it [1] and we found no later amendment, but confirm the current fee with the DCAA.

A fine "will be doubled if the same violation is repeated within one (1) year", and "A fine must not exceed one million Dirhams (AED 1,000,000.00)" [2]. The DCAA can also warn, suspend the activity for up to six months or revoke the permit.

The renewal conflict

Resolution No. 20 of 2023 says a renewal application "must be submitted within thirty (30) days from the date of its expiry" [1]. Resolution No. 4 of 2017 says it "must be submitted at least thirty (30) days prior to the date of its expiry" [2]. The safe reading is the earlier one: renew before expiry, never after.

Pro Tip: Diarise the DCAA renewal 30 days before the expiry date on the permit, with the trade licence renewal just ahead of it, because the permit depends on a valid commercial licence. Late renewal costs 10% of the AED 6,500 fee for every month or part month, AED 650 a month, and meanwhile you are trading without a permit [2].

The 2026 duties

Executive Council Resolution No. 15 of 2026, issued 12 May 2026, requires permit holders to follow "the relevant technical manuals approved by the DCAA", not to alter "any data or documents on the basis of which a permit" was issued without DCAA approval, to provide data on request, to admit inspectors, and to "develop and implement a risk management assessment plan for civil aviation-related activities in accordance with the model specified by the DCAA" [8]. That list is written for a "Practitioner"; confirm with the DCAA whether a parts trader counts as one.

Do aircraft parts traders need a GCAA approval?

No GCAA approval for aircraft parts distributors or stockists was found in CAR-M Issue 04, CAR-145 Issue 09 or CAR 21, in the issues we read; check the GCAA site for later issues. The GCAA's rules bind the buyer instead: an operator or maintenance organisation may fit only properly released parts, so the trader's paperwork decides every sale.

CAR-M M.501(a) says "No component may be fitted unless it is in a satisfactory condition, has been appropriately released to service", and that components "shall be released on an AW Form 1 or equivalent" [3]. CAR-145 repeats the acceptance rules for maintenance organisations [4]. All of it is addressed to your customer, whose quality department rejects an uncertified part at goods-in. Some marketing pages claim a GCAA trading approval exists; we found no regulation that says so, so ask the GCAA in writing if anyone insists.

Real Talk: Needing no approval is not the same as facing no standard. A UAE trader is judged by the certificates it supplies, the records it keeps and how fast it quarantines a doubtful part. Customers' auditors and contracts enforce that standard, and it is harder to meet than most permits.

What paperwork makes an aircraft part sellable in the UAE?

An aircraft part is sellable in the UAE when it carries a release certificate the GCAA accepts: an AW Form 1, an EASA Form 1 from an approved Part 145 organisation, an FAA Form 8130-3, a TCCA Form One or a type certificate holder's new-part release. Standard parts need conformity evidence instead.

The release certificates the GCAA accepts

The GCAA's own certificate is the AW Form 1, the "Authorised Release Certificate" in Appendix II to CAR-M [3]; use that name, not "GCAA Form 1", in supplier contracts. The acceptable means of compliance to CAR M.501(a) lists the equivalents, and CAR-145 adds the UK form [3][4].

EASA Form 1, FAA 8130-3 and the TC holder's release cover most stock bought from Europe and North America. Older JAA Form One certificates are accepted only within dated limits, so treat pre-2005 paperwork as a question for the buyer.

Stock without paperwork

CAR-M is explicit: "Any item in storage without an AW FORM 1 or equivalent cannot be installed on aircraft registered in a UAE unless an AW FORM 1 is issued for such item by an appropriately approved maintenance organisation" [3]. That re-release means an inspection, sometimes a test or overhaul, priced by quote. Budget it into every no-paperwork purchase and assume some items will fail.

PMA parts

FAA Parts Manufacturer Approval (PMA) parts are accepted on UAE-registered aircraft under a CAR-145 note [4]. The part must be released on an FAA 8130-3 and either be listed in the type certificate holder's parts catalogue, maintenance data or a GCAA-approved STC, or be non-critical per the 8130-3 remarks block; the contracting CAMO must also authorise it. A US FAA memo of 2 April 2021, written after talks with the GCAA, confirms that reading: either of the first two tests, plus CAMO acceptance [9]. So a PMA part sells only to a customer whose CAMO has said yes.

Standard parts, raw material and consumables

CAR-M says "Standard parts shall only be fitted when accompanied by evidence of conformity traceable to the applicable standard", and for materials a Form 1 "is not normally issued and therefore none should be expected" [3]. "Items purchased in batches (fasteners etc.) should be supplied intact in the original equipment manufacturer (OEM) package", showing part number, batch number and quantity [3]. Splitting a batch into loose bags without keeping that link destroys its value.

Life-limited and unsalvageable parts

CAR-145 145.42(d) says components at their certified life limit or with a non-repairable defect are unsalvageable and "shall not be permitted to re-enter the component supply system" unless the limit is extended or an approved repair exists [4]. Mutilate or segregate such parts and keep a record.

What the buyer inspects at goods-in

The acceptable means of compliance to CAR M.501(a) tells the installer what to check on arrival, which is the test your shipment faces [3]:

• the general condition of the part and its packaging;
• "verify that the shelf life of the component has not expired";
• correct packaging for the type, such as ATA 300 or electrostatic-sensitive packaging;
• plugs and caps fitted, with the instruction that "Tape should not be used to cover electrical connections or fluid fittings/openings".

Common Mistake: Buying teardown stock without back-to-birth records. The GCAA's safety alert on unapproved parts says the aircraft's records before storage "will need to be researched" to establish maintenance history and modification status [10]. Without that history, a maintenance organisation may refuse to re-release the part, and the lot you bought by weight stays on the shelf. Make the records a condition of the price.

How should a trader handle suspected unapproved parts?

A UAE aircraft parts trader should screen every purchase against the red flags in GCAA Safety Alert 05/2014, quarantine anything doubtful, and keep traceability records for every part number and serial number. The alert binds UAE operators and approved maintenance organisations, who report through ROSI; a trader's duty is commercial and contractual.

What the safety alert says

GCAA Safety Alert 05/2014, issued 30 June 2014, covers suspected unapproved parts and parts from retired or accident aircraft [10]. The copy we read is hosted by a third party, not the GCAA, so check with the GCAA that it still stands. Its applicability is "UAE Operators and Approved Maintenance Organisations", reporting through the GCAA's ROSI system read with CAAP 22 [10].

Its opening belongs on a trader's wall: "Documentary evidence of compliance with an approval process will not in itself provide a guarantee against the installation of a suspected unapproved part if the original supplier of such a part knowingly provided false information or otherwise sets out to deceive." [10]. Your process has to check the paper and the part.

The red flags

Six of the alert's warning signs at receipt, quoted exactly [10]:

For accident salvage the alert is blunt: "it is essential to obtain clear evidence" that an item was unaffected, and "If such evidence cannot be obtained, the item may not be returned to service." [10].

A quarantine and traceability procedure

No rule we read sets a trader's procedure, so build one your customers' auditors will accept. The alert says a part's documents may show the issuing authority, a traceability reference, the issuer's approval reference, an invoice number, part and serial number, life limits with in-service history, and a serviceable tag [10]. A workable procedure:

1. Receive into quarantine; nothing reaches saleable stock unchecked.
2. Match paper to part: part number, serial, batch and status against the data plate and purchase order.
3. Verify the certificate at source with the issuing organisation for high-value or unfamiliar suppliers.
4. Segregate rejects in a locked area with a record, and mutilate unsalvageable parts.
5. Keep the trail of supplier, certificate, check and buyer for every serial number, so you can recall a part.

Pro Tip: Write the quarantine procedure before your first purchase, not after your first rejection. Airline and maintenance buyers audit suppliers, and a one-page receiving procedure, a quarantine cage and a serial-number log are what they usually ask to see first. The cost is shelving and a lock.

Do aircraft parts traders need ASA-100 or AS9120 accreditation?

ASA-100 and AS9120 accreditation is voluntary for UAE aircraft parts traders: no GCAA requirement was found. The US FAA's Advisory Circular 00-56B, dated 27 May 2015, describes a voluntary distributor accreditation programme under which an accreditation lasts 36 months with surveillance audits. Many airline buyers still prefer accredited suppliers.

The circular says: "This AC is not mandatory and does not constitute a regulation." [11]. It names ASA-100 and AS9120 among acceptable quality standards, with an audit "at least once every 36 months" and "at least one surveillance audit during the 36-month term" [11]. The GCAA texts we read do not mention it.

So treat accreditation as a sales decision. If your buyers are airlines that score suppliers, or you want to sell into the US, price it early; audit and consultant fees are quotes from the accrediting bodies. Check that the circular edition you work to is still current.

Which UAE export controls apply to aircraft parts?

UAE export controls apply to aircraft parts under Federal Decree-Law No. 43 of 2021, across the whole country including free zones, and cover export, re-export, transit and brokerage. Most civil parts are not controlled as a class, but engines, avionics and navigation items need checking against Categories 7 and 9 of Cabinet Resolution No. 156 of 2025.

The law and the regulator

We could not read the official text of Federal Decree-Law No. 43 of 2021 on commodities subject to non-proliferation controls, so this relies on a dated law-firm analysis. Morgan Lewis, on 27 August 2025, describes the regime as applying across the whole of the UAE, free zones included, covering export, re-export, transit and brokerage, regulated by the Executive Office for Control and Non-Proliferation (EOCN), with a catch-all power over unlisted goods where proliferation use is suspected [12].

The control list

The current list is the annex to Cabinet Resolution No. 156 of 2025, dated 4 November 2025, including Category 7, navigation and avionics, and Category 9, aerospace and propulsion [13]. Civil parts are not controlled as a class. Note 1 to entry 9A001, for example, excludes aero gas turbine engines certified by EU or Wassenaar-state civil aviation authorities and intended to power non-military manned aircraft with a civil type certificate [13]. Military-designed goods sit on the separate UAE Munitions List.

General Note 2 closes the obvious loophole: "The object of the controls contained in this Annex should not be defeated by the export of any non-controlled goods (including plant) containing one or more controlled components when the controlled component or components are the principal element of the goods and can feasibly be removed or used for other purposes." [13].

The working rule: classify every part number before export, look hardest at engines, avionics, navigation items and anything for military or unmanned aircraft, and ask the EOCN before you ship when in doubt.

End-user checks and the US re-export risk

US-origin parts carry US rules wherever they are re-sold. On 17 June 2024 the US Commerce Department published a temporary denial order against Turboshaft FZE of SAIF Zone in Sharjah, Treetops Aviation of Dubai and others [14]. It states: "Import data reveals that 502 separate shipments, at least some of which consisted of aircraft parts, arrived in Russia between April 2022 and December 2023" [14]. It records the business being described to US officials in 2019 as "purchasing the parts at low prices and then reselling them for use in the urgent repair of grounded aircraft" [14], the same AOG model many honest traders run.

So an urgent order from an unfamiliar buyer, for an aircraft type the buyer's country is not known to operate, needs a written end-user statement and screening before anything ships.

Real Talk: If a deal only works because nobody asks where the aircraft is, do not do it. A denial order shuts a trader out of US-origin supply, and the order above names companies and individuals in Sharjah and Dubai [14]. No margin on one urgent shipment is worth losing the parts your other customers need.

How do customs duty and VAT apply to aircraft parts?

Aircraft parts fall under HS heading 8803, and no official UAE duty rate or exemption for them was found, so confirm the rate with Dubai Customs. For VAT, parts sold for a qualifying commercial aircraft can be zero-rated, exports on an air waybill are zero-rated, and a sale to another UAE trader for stock is 5%.

Customs

HS heading 8803 covers parts of aircraft. We found no official UAE tariff line, rate or exemption for it, so we state none: ask Dubai Customs or your clearing agent for the rate on your codes before pricing mainland sales. Our Dubai Customs registration guide covers the registration itself.

VAT on a parts sale

Four rules from the VAT Executive Regulation, consolidated to 18 September 2025, decide most parts invoices [15]:

• Qualifying aircraft. Article 34(1) covers "An aircraft that is designed or adapted to be used for commercial transportation of passengers or Goods and which is not designed nor adapted for recreation, pleasure or sports."
• Parts for those aircraft. Article 35(1) zero-rates "Goods, except fuel or other oil or gas products, that are supplied or imported in the course of operating, repairing, maintaining or converting such means of transport", if incorporated into the aircraft or used up as consumables.
• Exports. Article 30 zero-rates goods exported within 90 days with a customs declaration and commercial evidence such as an "Air waybill or air manifest". For an indirect export it adds: "The Goods do not leave the State in the possession of a passenger or crew member of an aircraft or ship." A move into a Designated Zone is not an export.
• Designated Zones. Article 51 treats a fenced, customs-controlled Designated Zone as outside the State for goods, subject to its conditions.

Dubai Airport Free Zone and Dubai Aviation City are on the Designated Zone list; Dubai South is not listed by that brand name [7].

The buyer and the route out of the country decide the invoice, not the part number.

Quick Math: AED 200,000 of parts sold to a UAE trader for its stock carries 5% VAT, AED 10,000 on the invoice. The same parts exported to an overseas buyer on an air waybill, with the customs declaration kept, are zero-rated: AED 0 [15]. Same parts, same price; only the buyer and the paperwork differ.

VAT registration is mandatory once taxable supplies pass AED 375,000 a year [19]; our VAT registration and compliance guide covers the returns.

Common Mistake: Zero-rating an AOG part a courier carried in a suitcase on a passenger flight. Article 30 needs commercial evidence such as an air waybill, and for an indirect export the goods must not leave "in the possession of a passenger or crew member" [15]. Unless another zero rate applies, the trader owes 5% on a sale priced as tax-free. Ship AOG parts as cargo.

Can an aircraft parts trader pay 0% corporate tax?

An aircraft parts trader can reach 0% corporate tax only as a Qualifying Free Zone Person whose income fits Ministerial Decision No. 229 of 2025. Parts are not Qualifying Commodities, but distribution from a Designated Zone to resellers or processors and leasing of rotable components can qualify; sales to airlines fitting their own fleets are hard to fit.

Why trading itself does not qualify

The trading limb of Ministerial Decision No. 229 of 2025 covers "Qualifying Commodities", defined as commodities with a quoted price: "Metals, minerals, industrial chemicals, energy and agriculture commodities and Associated By-products, excluding products packaged for retail sale" [16]. Aircraft parts are not on that list.

The distribution route

Item (l), distribution in or from a Designated Zone, can work. The activity must be conducted in or from a Designated Zone, goods entering the UAE must be imported through it, and the goods must go to "A customer who resells, processes or alters such goods or materials, or parts thereof for the purposes of sale or resale", or a public benefit entity [16]. Sales to other traders fit. Sales to maintenance shops that process parts into work they sell can fit, depending on the facts. Sales to an airline fitting parts to its own fleet are hard to fit, because it neither resells nor processes the part for sale.

The rotables route

Item (k), financing and leasing of aircraft, expressly includes rotable components: it covers "granting the right to use Aircraft, Aircraft engines or rotable components in exchange for rental or other consideration pursuant to a finance lease, operating lease or other arrangement" [16]. A lease pool, or an exchange structured as a right to use in return for a fee, can sit inside item (k). An outright sale is not named, and an exchange that simply swaps title looks like a sale, so have the contract reviewed. The aircraft leasing company guide covers item (k) further.

De minimis and the other traps

Transactions with natural persons are excluded activities, except under items (e), (g), (h) and (k) [16]. Non-qualifying revenue must not exceed "5% (five percent) of the total Revenue of the Qualifying Free Zone Person in that Tax Period or AED 5,000,000 (five million dirhams), whichever is lower" [16]. A free zone parts trader with large direct airline sales will fail that test.

Quick Math: A Designated Zone parts trader with AED 30,000,000 of revenue can earn non-qualifying revenue of the lower of 5% of revenue (AED 1,500,000) and AED 5,000,000, so the ceiling is AED 1,500,000 [16]. If its sales to airlines fitting their own fleets reach AED 1,600,000, it fails de minimis for that period, however small that share looks.

A company that fails a condition is taxed at the ordinary rates, 0% on taxable income up to AED 375,000 and 9% above, from the start of that tax period, and loses Qualifying Free Zone Person status for the following four periods [17]. A small trader may prefer Small Business Relief, for revenue at or under AED 3,000,000 in tax periods ending on or before 31 December 2029 under Ministerial Decision No. 131 of 2026 [18], which a Qualifying Free Zone Person cannot claim. Our guides to the Qualifying Free Zone Person rules and Small Business Relief to 2029 cover both.

How do AOG desks, consignment stock and exchanges affect cash?

Aircraft parts trading runs on three models: an AOG desk answering urgent orders, consignment stock placed at a customer's base, and rotable exchanges or pools. Each ties up cash differently, and each changes where the risk sits on release paperwork, export screening and the VAT invoice.

The AOG desk

An aircraft on ground (AOG) order is the most profitable and most dangerous sale in the business: the buyer needs the part now, pays for speed and asks fewer questions, which is the pattern in the US order above [14]. An AOG desk needs pre-vetted suppliers, certificates it can verify fast, a cargo route that produces an air waybill, and someone on call allowed to say no. A broker without stock still needs the licence and, in Dubai, the DCAA permit, because SN 21 covers resale [1].

Consignment stock

Under consignment, the trader places stock at the customer's base and is paid when a part is used. The trader carries all the inventory risk, so settle who insures the stock, who quarantines returned parts, how shelf life is tracked and when title passes, because title decides the VAT invoice.

Exchanges and pools

A rotable exchange swaps a serviceable unit for the customer's unserviceable core, which the trader has overhauled. Cash sits in the pool and the overhaul invoices, and every returning core needs its condition and history checked before acceptance. Structured as a right to use for a fee, a pool may reach item (k).

Real Talk: In this trade, paperwork sells stock. A warehouse of parts without verifiable certificates is a cost, not an asset. A new trader usually does better with a narrow range of well-documented parts for a few aircraft types than with a broad range bought cheaply by weight.

Expect banks to ask about your suppliers, buyers' countries and export screening; the corporate bank account guide covers account opening.

What does an aircraft parts trading company cost in its first year?

An aircraft parts trading company in Dubai costs from AED 21,850 with one visa in Dubai South or Meydan Free Zone, or AED 26,900 on the mainland, plus the DCAA permit at AED 6,500 under the 2017 schedule. Warehouse, accreditation and insurance are quotes, and BusinessDubai.ae packages cover company formation only.

The table itemises the first year for a Dubai trader with one visa. Package prices are BusinessDubai.ae's [19]; DCAA fees are from the 2017 schedule [2].

The predictable part is AED 28,350 for Dubai South with one visa plus the DCAA permit. The quotes are where budgets go wrong: a Designated Zone warehouse or the re-release of undocumented stock can each cost more than the licence. DAFZA, SAIF Zone and Abu Dhabi Airports Free Zone have no BusinessDubai.ae package and must be quoted by the zone.

Get an itemised quote for your parts business→

If your customers are in Abu Dhabi, our business setup in Abu Dhabi page shows the options; we found no Abu Dhabi equivalent of the DCAA list, so ask the zone and civil aviation authority what applies. Sharjah traders can compare business setup in Sharjah routes, including SPC Free Zone, with the same check.

Which setup fits your aircraft parts business?

The right aircraft parts setup depends on the stock and the customer. A new-parts distributor and a rotables pool fit a Dubai Designated Zone; a trader selling mainly to UAE airlines fits the mainland; an AOG broker needs a licence and DCAA permit without a warehouse; and a trader shipping to sanctioned-risk regions should not start.

The last row is a plain no: UAE export control law reaches free zones, US re-export rules follow US-origin parts, and the US denial order above shows where it ends [12][14].

Real Client Stories

These are composite examples built from the situations aircraft parts trading founders most often face in the UAE. Names and details are illustrative, and the only figures used are published government fees and BusinessDubai.ae's package prices.

Omar's teardown lot (Dubai South)

Omar, a Jordanian engineer, set up in Dubai South at AED 21,850 with one visa and took the DCAA permit at AED 6,500 under SN 21. His first big purchase was a teardown lot from a retired narrowbody, priced by weight. Many parts came without records back to the source aircraft, and the approved maintenance organisation he asked would not re-release them without that history. He had also not added SN 1 for used parts, so he applied to DCAA to add it to his permit and put the undocumented parts into quarantine.

Lesson: buy used parts on records, not on weight, and licence for used stock from day one.

Priya's AOG desk (IFZA)

Priya, an Indian former airline buyer, licensed an AOG brokerage in IFZA at the AED 22,200 partner price with one visa, holding no stock. Her first urgent order came from an overseas operator, and she sent the part with a courier on a passenger flight to save a day. She invoiced at 0%, but the part had left the country in a passenger's possession with no air waybill, so the sale did not meet the export conditions. She paid the 5% herself and moved every AOG shipment to air cargo.

Lesson: an urgent part still needs an air waybill if the invoice is zero-rated.

Viktor's Sharjah order book (SPC Free Zone)

Viktor, a Ukrainian founder, chose SPC Free Zone for its AED 15,055 package with one visa. He first asked the zone in writing to confirm that aircraft parts trading was on its activity list and asked the civil aviation authority what approval applied outside Dubai. Within weeks he received a large engine-parts enquiry from a new buyer, routed through a third country, with no named operator. He asked for an end-user statement and the aircraft registration. The buyer stopped replying.

Lesson: an end-user question that loses a doubtful order has done its job.

Start your aircraft parts trading company the right way

An aircraft parts trading company in the UAE succeeds on three decisions: the right activities and, in Dubai, a DCAA permit renewed before it expires; a paperwork and quarantine system that only buys parts a UAE buyer can fit; and export and tax checks on every sale, because the buyer and the route decide both.

BusinessDubai.ae has completed 700+ company registrations across the UAE, with itemised pricing and no hidden fees. We will price a free zone company setup in Dubai South, Meydan or IFZA against a mainland company setup for a trader selling to UAE airlines, put the right parts activities on the licence, and say plainly where a zone such as DAFZA must quote directly. After setup, our post-setup services team runs the licence, visa and VAT calendar so the DCAA renewal never lapses.

Talk to a setup expert about your parts business→

Frequently Asked Questions

Which activity code covers aircraft spare parts trading in Dubai Airport Free Zone?

Dubai Airport Free Zone's ISIC Activity List 2025 uses 4773-708 for aircraft spare parts and components trading and 4669-109 for aircraft scrap and used spare parts. DAFZ says the list is not final and some activities need an NOC.

Can one licence cover both new and used aircraft parts?

Yes, but they are separate entries: DAFZ uses 4773-708 and 4669-109, and the DCAA lists new parts as SN 21 and used parts as SN 1. Put both on the licence and permit if you might buy used stock.

How much does the DCAA permit cost for an aircraft parts trader?

The DCAA permit costs AED 6,500 to issue or renew under Schedule 1, item 6 of Executive Council Resolution No. 4 of 2017. No later amendment was found as of November 2026; confirm the fee with the DCAA.

How long does the DCAA take to decide a permit application?

The DCAA decides within ten working days of the application under Administrative Resolution No. 20 of 2023. If it refuses, it gives reasons and you may apply again.

When should I renew the DCAA permit?

Renew the DCAA permit before it expires, ideally 30 days ahead. Resolution No. 4 of 2017 says at least 30 days before expiry, while Resolution No. 20 of 2023 says within 30 days from expiry. Late renewal costs 10% of the fee per month of delay.

What is the fine for trading aircraft parts in Dubai without a DCAA permit?

The fine is AED 10,000 under Schedule 7 of Executive Council Resolution No. 4 of 2017, doubled for a repeat within one year and capped at AED 1,000,000. The DCAA can also warn, suspend the activity for up to six months or revoke the permit.

Do I need a DCAA permit in a Dubai free zone?

Yes. Administrative Resolution No. 20 of 2023 defines the Licensing Authority to include free zone authorities, so a trader licensed in DAFZA, Dubai South, Meydan or IFZA needs the DCAA permit like a mainland trader.

Does an aircraft parts trader in Sharjah or Abu Dhabi need a DCAA permit?

No, the DCAA permit applies to Dubai. We found no equivalent published list for Sharjah, Abu Dhabi or Ras Al Khaimah, so ask your zone and the relevant civil aviation authority in writing what applies.

Do aircraft parts traders need GCAA approval?

No GCAA approval for parts distributors or stockists was found in CAR-M Issue 04, CAR-145 Issue 09 or CAR 21 as read in 2026. The GCAA's rules bind buyers instead: an operator or maintenance organisation may fit only parts released on an AW Form 1 or an accepted equivalent.

Is an EASA Form 1 accepted on UAE-registered aircraft?

Yes. The GCAA's CAR-M lists an EASA Form 1 from a Part 145 organisation approved by an EASA member state or EASA as equivalent to the AW Form 1, the GCAA's own release certificate. CAR-145 Issue 09 also accepts a UK CAA Form 1.

Are PMA parts allowed on UAE-registered aircraft?

Yes, FAA PMA parts are allowed if released on an FAA 8130-3 and either listed in the TC holder's catalogue, maintenance data or a GCAA-approved STC, or marked non-critical. The contracting CAMO must also accept them, per an FAA memo of 2 April 2021.

Can I sell aircraft parts that have no Form 1?

You can sell them, but a UAE buyer cannot fit them. CAR-M says an item in storage without an AW Form 1 or equivalent cannot be installed on a UAE-registered aircraft until an appropriately approved maintenance organisation issues one. Budget for that re-release.

Do standard parts like bolts need a Form 1?

No. Standard parts need evidence of conformity traceable to the applicable standard, and CAR-M says a Form 1 is not normally issued for raw and consumable material. Batch items such as fasteners should come intact in OEM packaging showing part number, batch and quantity.

Can I sell life-expired or scrapped aircraft parts?

Not into the supply chain. CAR-145 145.42(d) says components at their certified life limit or with a non-repairable defect are unsalvageable and must not re-enter the component supply system unless the limit is extended or an approved repair exists. Segregate or mutilate them.

Who reports suspected unapproved parts in the UAE?

UAE operators and approved maintenance organisations report suspected unapproved parts to the GCAA through ROSI, read with CAAP 22, under GCAA Safety Alert 05/2014. Traders are not named, but their customers are, so quarantine and record any doubtful part.

Do I need ASA-100 or AS9120 accreditation to trade aircraft parts in the UAE?

No, accreditation is voluntary and no GCAA requirement was found. The FAA's Advisory Circular 00-56B of 27 May 2015 says it is not mandatory; an accreditation lasts 36 months with at least one surveillance audit. Many airline buyers prefer accredited suppliers.

Are aircraft parts dual-use goods under UAE law?

Not as a class. Cabinet Resolution No. 156 of 2025 controls specified items, with Category 7 covering navigation and avionics and Category 9 aerospace and propulsion, and excludes some civil-certified aero engines. Classify every part number and ask the EOCN when in doubt.

Do UAE export controls apply in free zones?

Yes. Federal Decree-Law No. 43 of 2021 applies across the entire UAE, including free zones, and covers export, re-export, transit and brokerage, according to Morgan Lewis's analysis of 27 August 2025. The regulator is the Executive Office for Control and Non-Proliferation.

Can I re-export US-origin aircraft parts to Russia?

US rules have required licences for aviation-related items to Russia since 24 February 2022, and they follow US-origin parts after re-sale. A US temporary denial order published 17 June 2024 named traders in Sharjah and Dubai over aircraft parts shipments to Russia. Do not ship.

Is there customs duty on aircraft parts in the UAE?

Aircraft parts fall under HS heading 8803, but no official UAE duty rate or exemption for them was found as of November 2026. Confirm the rate for your codes with Dubai Customs.

Is VAT charged on aircraft parts sold to a UAE airline?

Parts sold to a UAE airline or MRO in the course of operating, repairing or maintaining a qualifying commercial aircraft can be zero-rated under Article 35 of the VAT Executive Regulation, if the parts are fitted. Keep the evidence. A sale to another UAE trader for stock is 5%.

Can I zero-rate an AOG part hand-carried out of the UAE?

Usually not. Article 30 of the VAT Executive Regulation needs export evidence such as an air waybill, and for an indirect export it says the goods must not leave in the possession of a passenger or crew member. Ship AOG parts as air cargo if you want the 0% rate.

Can an aircraft parts trader get 0% corporate tax in a free zone?

Sometimes. Parts are not Qualifying Commodities under Ministerial Decision No. 229 of 2025, but distribution from a Designated Zone to customers who resell or process the goods can qualify. Sales to airlines fitting their own fleets count as non-qualifying revenue and can break de minimis.

Does leasing rotable components qualify for 0% corporate tax?

It can. Item (k) of Ministerial Decision No. 229 of 2025 covers granting the right to use aircraft, engines or rotable components for rental under a lease or other arrangement. An outright sale of rotables is not named, so structure and document an exchange or pool carefully.

Can a small aircraft parts trader use Small Business Relief?

Yes, if revenue is at or under AED 3,000,000 in tax periods ending on or before 31 December 2029, under Ministerial Decision No. 131 of 2026. A company cannot claim it while it is a Qualifying Free Zone Person, so choose one route.

How much does it cost to set up an aircraft parts trading company in Dubai?

Through BusinessDubai.ae, a Dubai South or Meydan Free Zone package with one visa costs AED 21,850 and a Dubai mainland package AED 26,900, plus AED 6,500 for the DCAA permit. Packages are company formation only.

References

[1] Dubai Legislation Portal. Dubai Civil Aviation Authority Administrative Resolution No. (20) of 2023 Approving the Conditions for Aviation Permits, issued 7 June 2023: Articles 1 to 4 (Licensing Authority definition, the four permit conditions, ten working day decision, one-year validity and renewal wording) and the List of Civil Aviation-related Activities, items SN 1, 15, 21 and 26 quoted verbatim. dlp.dubai.gov.ae

[2] Dubai Legislation Portal. Executive Council Resolution No. (4) of 2017, issued 30 January 2017: Article 1 permit requirement and renewal timing, Article 2 fees and assessment costs, Article 3 penalties, Schedule 1 items 6 to 8, Schedule 5 inspection and NOC fees, Schedule 7 fines including late renewal. dlp.dubai.gov.ae

[3] General Civil Aviation Authority. CAR Part V Chapter 4, CAR-M Continuing Airworthiness Requirements, Issue 04: CAR M.501 and its acceptable means of compliance (AW Form 1 and equivalents, PMA note, stock without release, standard parts, materials, batch packaging, receiving checks) and Appendix II. gcaa.gov.ae

[4] General Civil Aviation Authority. CAR-145 Approved Maintenance Organisation, Issue 09 (issued 10 January 2023, applicable 1 March 2023): 145.42(d) unsalvageable components and AMC 145.42(a)(1) acceptance of components, including UK CAA Form 1 and the FAA PMA note. gcaa.gov.ae

[5] Dubai Airport Free Zone. ISIC Activity List 2025: activities 4773-708 and 4669-109 with their descriptions, and the note that the list is not final and NOCs are required for certain activities. dafz.ae

[6] Dubai Department of Economy and Tourism. Business activity list as recorded in a public copy of the register: activities 4773708, 4669109, 5210010 and 3315005, names, licence types and the 4669109 description.

[7] Federal Tax Authority. List of Designated Zones, consolidated to Cabinet Decision No. 81 of 2021: the Dubai Airport Free Zone, Dubai Aviation City and Sharjah Airport International Free Zone entries. tax.gov.ae

[8] Dubai Legislation Portal. Executive Council Resolution No. (15) of 2026 applicable to operators, civil aviation-related professions and activities, issued 12 May 2026: Article 2 technical manuals, Article 4 obligations of Practitioners and Article 5 penalties. dlp.dubai.gov.ae

[9] US Federal Aviation Administration. Memorandum of 2 April 2021, UAE Regulations on the Eligibility of U.S. FAA PMA parts on UAE-Registered Aircraft: the GCAA's confirmed reading of the PMA note. faa.gov

[10] General Civil Aviation Authority. Safety Alert 05/2014, Suspected Unapproved Parts and Parts Removed from Aircraft No Longer in Service or Involved in Accidents, issued 30 June 2014 (copy hosted by a third party, SAS Sofia): applicability, ROSI and CAAP 22 reporting, red flags, expected documentation, parting-out and accident salvage. sassofia.com

[11] US Federal Aviation Administration. Advisory Circular 00-56B, Voluntary Industry Distributor Accreditation Program, dated 27 May 2015: non-mandatory status, ASA-100 and AS9120 standards, 36-month audit and surveillance cycle. faa.gov

[12] Morgan Lewis. Overview of the UAE's Export Control Regime, LawFlash updated 27 August 2025: scope of Federal Decree-Law No. 43 of 2021 including free zones, re-export, transit and brokerage, the EOCN and the catch-all control. morganlewis.com

[13] Executive Office for Control and Non-Proliferation. Cabinet Resolution No. 156 of 2025 on the schedule of commodities subject to control and non-proliferation, dated 4 November 2025: categories 7 and 9, General Notes 1 and 2, and 9A001 Note 1. eocn.gov.ae

[14] US Department of Commerce, Bureau of Industry and Security. Order Temporarily Denying Export Privileges, Turboshaft FZE, Treetops Aviation and others, Federal Register document 2024-13257, published 17 June 2024: the 502 shipments finding, the 2019 description of the business and the February 2022 aviation controls on Russia. federalregister.gov

[15] Federal Tax Authority. Executive Regulation of Federal Decree-Law No. 8 of 2017 on Value Added Tax, consolidated 18 September 2025: Article 30 exports, Article 34 qualifying means of transport, Article 35 related goods and Article 51 Designated Zones. tax.gov.ae

[16] Ministry of Finance. Ministerial Decision No. 229 of 2025 Regarding Qualifying Activities and Excluded Activities: the Qualifying Commodities definition, items (k) and (l), the natural persons exclusion and the Article 3 de minimis rule. mof.gov.ae

[17] Federal Tax Authority. Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses: 0% to AED 375,000 and 9% above, and Article 18 on Qualifying Free Zone Persons and loss of status. tax.gov.ae

[18] Ministry of Finance. Ministerial Decision No. 73 of 2023 on Small Business Relief, as amended by Ministerial Decision No. 131 of 2026: revenue at or below AED 3,000,000 for tax periods ending on or before 31 December 2029, not available to a Qualifying Free Zone Person. mof.gov.ae

[19] BusinessDubai.ae. Internal pricing reference: current company formation packages for the Dubai mainland, Dubai South, Meydan Free Zone, IFZA (partner price) and SPC Free Zone by visa count, the mainland renewal guide and the VAT registration threshold summary, as at 3 November 2026. businessdubai.ae