Fujairah Oil Industry Zone (FOIZ)Free zone tax status and compliance
Fujairah
Fujairah Free Zone Authority
The Verdict
The Energy Giant; Specialized in Extractive vs. Non-Extractive Forensic Splits.
I. Statutory Basis
As a Qualifying Free Zone Person, this jurisdiction requires strict adherence toCore Income-Generating Activities.Specific Oil Law overrides apply. Statutory nexus is defined by the intersection of Federal Decree-Law 47 (Article 2) and local Fujairah energy decrees. Requires specialized bunkering-bill audits.
Compliance Roadmap
Specialized Extractive Audit: Segmenting upstream 'Extractive' income (Exempt) from midstream 'Bunkering/Trading' income (Taxable/QFZP)
Bunkering Bill Forensic Trail: Reconciling ship-to-ship transfer logs with customs-bonded storage data to justify 0% QFZP status on trading
Article 34 Transfer Pricing: Establishing arm's-length benchmarks for inter-company fuel storage and throughput agreements
Audit Hotspots
Incorrectly applying Federal CT to 'Extractive' income that is already taxed at the Emirate level (Overpayment)
Failing to document CIGA for 'High-Seas' bunkering trades conducted from FOIZ offices
Inadequate ring-fencing of 'Storage Fees' which may be treated as non-qualifying income if not properly structured
Jurisdictional Connectivity
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