This decision defines 'Qualifying Income' for a Qualifying Free Zone Person (QFZP). It includes income from transactions with other Free Zone Persons and income from 'Qualifying Activities' with Non-Free Zone Persons. A cornerstone requirement is that the QFZP must undertake its core income-generating activities and maintain adequate substance (assets, qualified employees, operating expenditure) in the Free Zone. Income attributable to a Domestic or Foreign Permanent Establishment, or from certain immovable property transactions, constitutes 'Excluded Activities' and is taxed at the standard rate. The decision also details the de minimis requirements for including other income.