🇦🇪 UAEConglomerate
Corporate Tax Restructuring: Protecting a $2.1B Group's UAE Tax Position
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🇦🇪
UAE
International Trade
Business Setup International Trade UAE 11 weeks from initial engagement to first commercial shipment
International Trading Company: JAFZA Free Zone Establishment
11 weeks
Setup Timeline
0%
Tax Rate on Qualifying Income
14
Markets Served
$380M+
Annual Throughput
Client Profile
A European commodity trading firm with €240 million annual turnover seeking to establish a UAE hub for MENA and South Asia distribution.
Business Challenge
The client required a UAE entity capable of importing, warehousing, and re-exporting commodities across 14 markets while minimising tax leakage on trading margins. Their existing Mauritius holding structure was facing increased OECD scrutiny under BEPS Pillar Two.
Strategic Solution
ILS Consultancy designed a Qualifying Free Zone Person (QFZP) structure within Jebel Ali Free Zone (JAFZA), incorporating a dedicated trading entity, a separate warehousing SPV, and an intercompany pricing framework aligned with OECD transfer pricing guidelines. We coordinated with JAFZA, UAE Customs, and the FTA to secure all operational approvals within a single engagement.
Outcome
The entity became fully operational within the target timeline. The 0% corporate tax rate on qualifying trading income delivered an immediate 9% margin improvement versus mainland alternatives. The structure withstood Big Four transfer pricing review and is currently being used as the template for the client's Singapore-JAFZA corridor.
Timeline
11 weeks from initial engagement to first commercial shipment
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