Insights for Now 

Key Changes

Trading of QC

• Amendment in the definition of QC:
  • Omission of trading on exchange in raw form
  • Inclusion of industrial chemicals, by-products, environmental commodities, carbon credits
  • Exclusion of packaged retail products
• Introduction of Quoted Price
• Scope widened with the inclusion of “associated structured commodity financing activity”.
• Scope limited by exclusion of QFZPs with ≥51% revenue from distribution, warehousing, logistics or inventory management

Treasury & financing services

Scope expanded to include self-financing activities carried out by the QFZP.

Distribution goods or material in or from Designated Zone

Scope expanded to include goods or materials supplied to a public benefit entity.

Excluded Activity

Finance and leasing shall continue to be an EA except where such activity pertains to the QA of ‘Trading of QC’, inter alia, existing exclusions.

Impact on Tomorrow

Business Implications

Wider eligibility:

Structured commodity financing and environmental commodity traders may now access QFZP benefits, including the 0% CT rate, subject to meeting prescribed conditions.

Sectoral opportunities:

• Commodity traders gain recognition for hedging and structured finance
• ESG markets benefit from explicit coverage of carbon credits and renewable energy certificates.
• Distributors can supply to public benefit entities without breaching de-minimis rules.

Strategic impact:

Free Zones positioned as globally benchmarked hubs for trade, finance, and innovation.

Higher standards:

Clearer rules and audit obligations reinforce transparency and international credibility.

Next Steps

1. Reassess eligibility under the amended QA & EA.
2. Review CT returns since 1 June 2023; consider revisions if required.
3. Prepare for the first filing on 30 Sept 2025, factoring in retrospective effect the changes introduced.
4. Leverage the changes to align business models with new qualifying activities.