1 Knight Frank.co.

nz

ULUBUTA ESTATE, VANUA LEVU, FIJI

F O R S A L E | P R I V AT E T R E AT Y + E X P R E S S I O N S O F I N T E R E S T
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Contents
Introduction & Contact Details 3
Executive Summary 4
The Opportunity 5
The Location 6
Fiji Overview 7
Market Overview 8
Economics & Tourism 9
Key Investment Attributes 10
Target Market 11
Method of Sale 12
Disclaimer and Contact 13
Annexures
Certificate of Title
Fiji Tax & Customs Incentives
Basic Concept Deisgn
3 Knight Frank.co.nz

Bula.
Connecting people and property, perfectly.

Knight Frank New Zealand is proud to offer Ulubuta Estate for sale.

This Information Memorandum provides preliminary information to assist interested parties with
their assessment of the property.

This Information Memorandum is produced as a general guide only and does not constitute
valuation advice nor an offer for sale or purchase.

All parties should undertake and rely on their own independent due diligence investigations and
not rely on the information contained in this document to make their purchasing decision.

Knight Frank offers Ulubuta Estate for sale at an asking price of USD $3 million.

Sale & Purchase Agreement | Particulars and Conditions of Sale of Real Estate by negotiation is
provided upon request by Rick Kermode or Allen Beagley.

Rick Kermode Allen Beagley

Commercial Sales and Leasing Broker Nationa Director
Pacific Island Resort Specialist Hotels
+64 21 882 452 +64 27 220 2033
+64 3 377 3700 +64 9 377 3700
[email protected] [email protected]
4 Knight Frank.co.nz

Executive Summary
Legal Owner Project Design and Development Limited
Legal Descrption Certificate of Title 4663 as a freehold tenure extending to an area of 602 acres (243.6208 hectares).
Zoning Agricultural, It has approval for Special use (Tourism) and development plans have been made.
Address Visoqo Road, of Wainikoro Dama Road, Visoqo, Vanua Levu, Fiji | Coordinates - 179.66˚ East 16.22˚ South.
602 Acres (243.6208 hectares) of Freehold land.
Land
The site is almost flat towards the sea coast though rises as it goes further inland. We are advised that the soil is generally fertile and is suitable for the
growing of crops. Other areas can be used for grazing purposes. Overall it is of a regular shape with direct coastal frontage. Approximately 20 hectares of the
land is located between Visoqo Road and the coast. Visoqo Road runs across the property. The coast is largely covered in mangroves. The balance of the
property has steeper to rolling contours
At this time, the property being somewhat remote does not have electricity or reticulated water supply. There are further limited bus services available on
General Visoqo Road. Commercial facilities are available at: Wainikoro Government Station and Labasa commercial centre. The nearest airport is Labasa which
is 38 kilometres “as the crow flies” to the west. We are advised that the property offers a Special Use (Tourism) classification in accordance with the Fiji
Government’s vision for promoting development and tourism in Vanua Levu. A key point is the freehold nature of the property. A development concept plan
outlines hotels, golf course and sports ranch, tourist shopping and business centre, health clinic, villas and residential sites.

Other proposed major infrastructure requirements include:

• A land based seaport capable of accommodating equipment transfers and private yachts
• Deep water access for large vessels
• Roading to service the resort
• Electricity supply
• Water supply
• Wastewater disposal
• Stormwater treatment and detention system
• Communications
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Location
Ulubuta Estate is situated in the locality commonly known as Visoqo on the north coast
of Vanua Levu. Ideally positioned in the dry zone of the island and connected to Labasa
town by an all-weather partly sealed gravel surfaced road.

Labasa town is the main administrative centre of the northern division and several
Government departments and other institutions are stationed in this town.

Conveniently, flights to Labasa are 45 minutes from Nadi. This rural locality is 70
kilometres by road from Labasa town centre and 30 kilometres from Wainikoro
Government Station.

The property is accessible from Wainikoro Dama Road and then by Visoqo Road.

There are several villages located in this district close to the property.
6 Knight Frank.co.nz

Fiji’s Great Sea Reef along the western coastline of Vanua Levu is the world’s third largest barrier reef stretching 200 km.
The Great Sea Reef is home to an abundance of marine life and diverse aquatic species.
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The Opportunity
With Fiji being in the South Pacific approximately 17˚ below (south) of the equator has Ulubuta with this activity in the late 1800s then resulted in heavy siltation of water ways
over 333 islands scattered across azure waters. The Fiji tropical climate allows also and subsequent establishment of mangroves.
for an abundance of natural beauty and colourful sea life. Offering an idyllic tropical
resort opportunity featuring a unique configuration with a stunning beachfront once The proposed development project would require the removal of mangroves and silt
rehabilitated. Ulubutu provides for an natural, undisturbed habitat. thus reinstating the beach and water ways to their natural pristine state by utilising some
of the off shore white sand deposits. This would be a similar approach to the beach at
Currently used for agricultural purposes, plans are available for a proposed resort and Denarau.
development plan (see appendices). The opportunity then exists to either resurrect this
proposed development plan or consider a greenfields development given its coastal The integrated resort development could encompass hotels, golf course, commercial
positioning. and residential development. In fact, this will be a greenfields development to allow for
complete establishment of: Infrastructure – power, water, roading, communications and
Offering a 1.2 kilometre coastal frontage, the property extends to approximately 1.5 fibre optic.
kilometres inland. With the land rising inland from the coast to undulating terrain and a
ridge traversing the property in a north south direction. The ridge is approximately 1.2 A blank canvas with a multitude of development opportunities. Several villages
kilometres from the coast with an elevation of approximately 100 metres. are located nearby the Ulubuta site providing a local labour force and cultural
experience.
Significant earthworks are proposed over some of the areas to create optimal
residential building sites. The proposed upper level resort hotels and villas could offer
uninterrupted panoramic vistas of the outer islands and coral reefs.

The lower slopes and level areas are partially vegetated with tropical shrubs and palms,
whilst the higher areas are sparsely cladd with several species of Melaleuca (native
grasses) which have grown wild as a result of deforestation.

There is proposed large-scale planting of native trees, shrubs and coconut palms to
recreate an aesthetic tropical setting.Early deforestation resulted in an uncontrolled
situation around the Vanua Levu coastal environ.
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Fiji
Climate | Ulubuta is located on the dry side of the island with an average rainfall of
200mm per month.

Summer temperatures (November – March), range between 24˚C – 27˚C and in winter
(April – October) they range between 20˚C – 26˚C. A cooling trade wind blows from the
southeast for most of the year.

Government | Fiji has endured coups during 1987, 2000 and 2006. While there
has been an initial hiatus post-coup with visitor arrivals decreasing this recovered.
It is interesting to note that the economic recovery period has decreased from
approximately three years in 1987 to the most recent coup 2006 being less than one
year.

There was a period of political uncertainty though foreign investment was untouched.
Pressure was exerted on the Fijian Government by other countries (New Zealand,
Australia) to hold democratic elections. These were held in September 2014.
Notwithstanding the fact that there was a global financial crisis, (GFC – 2007-2013)
the political environment in Fiji has created other issues, in particular from an export
perspective. While we cover this in the ‘Economic and Tourism’ section the fact
remains that investor confidence was severely eroded with the ongoing political
uncertainty and a challenging economic environment. This has now improved with
foreign reserves increasing since 2011 and a stabilising balance of payments.

Legal | The legal system is based upon the British system with the judiciary operating
through the Supreme Court, Court of Appeal, High Court and Magistrates Court. With
the most recent coup, the Government scrapped the constitution and dismissed the
judiciary. This was reinstated in September 2013.
9 Knight Frank.co.nz

South Pacific
• The Fiji Islands are located between: lattitude 12° south and 21° south & Longitude 17° east and 178° west
• They offer a total land area of 18,376 square kilometres
• Fiji has a total of 844 islands and islets with only 106 inhabited

Fiji Islands
• Ulubuta is located in Visoqo to the north coast of Vanua Levu
• Approximately 45 minutes flying time to the north east of Nadi
• All weather gravel road access is available to the property
• Idyllic tropical resort development opportunity
• Beach front positioning

Ulubutu
• A 602 acre (243.6208 hectare) development opportunity with agricultural zoning
• Option for Special Use (Tourism) in accordance with the government’s vision for promoting development & tourism
• Limited improvements on the land allows for a blank canvas to develop.
• Potential to develop a unique feature resort with beach frontage (1.2 kilometres),
• Ample water supply and almost unlimited options.
• The investors choice.
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Market Overview
There has been a surge of investment activity in Fiji. The Chinese have entered the Fiji is becoming sought after by investors, developers and tourists. Its national airline has
market setting up Fijian companies and acquiring various sites. These include The Fintel new aircraft and opened up new routes and destinations bringing a greater market to Fiji.
Building in Suva at the reported FJD $5.1 million along with other areas for mixed use, Confidence is high and we are at a poignant moment in the Fijian island and property
residential and development. market.
The Kiribati government have acquired 2000 hectares of land on CakauDrove with a
reported payment of USD $9 million. Knight Frank have sold the following leasehold islands: Nanuku Levu, Malima and have a
10,000 acre site on Vanua Levu which is under contract (listed at US$17M) and Nananu-i-
Chinese investment: cake a freehold island (550 acres listed at US$12M).
• 18 storey Hotel in Suva.
• Resort developments on the western coastline of Viti Levu. Knight Frank’s ‘Island Review 2015’ assessed current property market conditions across
the world’s top island destinations which resulted in these key findings:
There is also local investment taking place in Fiji as the Hilton Denarau was bought by a • Online viewings of island properties for sale increased by 21% in 2014 in
local Indian businessman. They also contracted Sonaisali Island Resort and Tadrai and comparison with a year earlier.
additional land for circa FJD $22 million. The Sonaisali was upgraded and rebranded • Tight planning restrictions are protecting prices on some islands.
“Double Tree Hilton”. This is a very good sign that local businesses are prepared to • In the last decade, there has been a 69% increase in private flights to island
invest in Fiji’s tourism sector and it reflects the ongoing growth and strength of this destinations.
market. • In Asia, the concept of a second home or “lifestyle” purchase is slowly becoming
more established and we expect this trend will increase significantly in the next
Further, the purchase of the Starwoods portfolio demonstrates the commitment of five years with major repercussions for global markets. Together Bali, Phuket and
investors in Fiji. The portfolio consists of the Sheraton, the Westin and the Denarau Golf Fiji represent the most mature island markets but they remain tourist destinations
Course and associated land. rather than established hotspots in the western model.

There is also the recently completed FJD $80 million spend on the Pearl Resort Hotel Further there has been strong interest in our resort listings and also larger parcels of
along with a marina development in Pacific Harbour. undeveloped land on Vanua Levu.

Fiji now has an elected government and this has opened many doors and re-established All this focuses to an improved economic activity for Fiji and with increasing tourism
relationships with its neighbours New Zealand and Australia. arrivals particularly from New Zealand and Australia and increasingly from China all
The economy in the region has improved and visitor numbers to Fiji are increasing. underpins the strength of the tourism industry.
11 Knight Frank.co.nz

Key Attributes
Ulubutu exudes the traditional Fiji hospitality. The warmth, friendliness and relaxation
uniquely blended with a Fijian landscape setting.

Its relationship with the sea, its lush tropical landscape and unique land forms within a
spectacular setting allow for the Fijian character to be exhibited and delivered.

• Freehold tenure is highly sought after as only 8% of Fiji land is freehold

• A blank canvas for development notwithstanding the fact there are limited
improvements from an infrastructural aspect at this time
• Beach front (1.2 kilometres)
• Potential subdivision to develop as a private retreat and individual private residences
in conjunction with marina, hotel and commercial utilities
• The property offers an exclusive location albeit remote
• Ulubutu’s remote nature creates a degree of exclusivity
• Modest commute from Nadi International Airport (45 minutes) to Labasa
• Direct helicopter or boat access
• Landscape allows for potential for numerous tourism developments
• The elevation allows for extensive vistas to the surrounding sea
• Expansion for some of the areas into horticulture or agriculture to supply the hotels
and other developments
• With this blank canvas, there is ability to explore all possible options
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Economics and Tourism

With respect to the Reserve Bank of Fiji and the most recent economic review for month Visitor Statistics | By way of purpose of visit we note for the year end in December 2016
ended July 2017 this noted that the economic environment remains ‘favourable’. Visitor that holidays still dominated 75.84% of all arrivals, representing 600,888 arrivals.
arrivals have remained strong in the year to June representing a 6.6% annual rise backed This was followed by VFR at 8.62%. Over 65% of arrivals come from New Zealand
by an increase from New Zealand, the USA, the rest of Asia and the Pacific Islands. (20.68% ) and Australia (45.48%).

From an economic standpoint cane and sugar production were higher by a significant Purpose of visit in 2016
74.9% and 77.7% respectively in the first eight weeks of crushing reflecting the recovery
of the impact from natural disasters during 2016. Both electricity and consumption Business Conference Holiday VFR Eduction Other
were also up. This is a reflection of improved economic conditions. 32,922 13,993 600,887 68,262 7,559 68,697
4.16% 1.77% 75.84% 8.62% 0.95% 8.67%
In summary, the key points are as follows:

• Year ended July 2017 – International Visitor Arrivals (IVA) 815,297

Purpose of visit in 2016 Market Share IUA Year end 2016
• Increasing visitor by percentage with a 6.6% increase for the year ended June 2017
• Significant increase in both cane and sugar production
• Electricity and consumption increased annually by 8.2% and 7.7% respectively Japan 1%
• New bank lending grew by 8.4% for consumption purposes UK 2%
• Positive labour market conditions
• Accommodative monetary conditions supported by economic activity Europe 4%

• Increasing bank liquidity and foreign reserves Holiday Other 6%

• Foreign reserves are sufficient to cover 5.7 months of retained imports & goods Other
China 6%
• The FJ$ appreciated against the Japanese Yen and the $US VFR
Business
• The FJ$ depreciated against the $NZ, $AUS and Euro. Conference Pacifi Islands 6%
• A continuing decrease in annual inflation which was 2% in June 2017 down slightly Education
USA 9%
from 2.5% in May 2017.
New Zealand 21%
• The Reserve Bank Board have kept the Overnight Policy Rate (OPR) unchanged at
0.5% in July due to recent economic developments, the outlook and the monetary Australia 45%
policies objective given stable inflation and increasing foreign reserves.
0% 10% 20% 30% 40% 50%
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Economics and Tourism

Turning to arrivals since 2011 this has shown a compound growth of 3.2%. Tourism Earnings | Tourism is now the largest source of foreign exchange earnings in
comparison with earnings from other industries such as sugar, fisheries, garments and
Growth of arrivals by year forestry. In 2010 earnings for tourism were FJ$1.2B and for the period 2011 – 2015 they
averaged FJ$1.4B. For the year ended 2016 this was FJ$1.6B or 16% of GDP. In short
2011 2012 2013 2014 2015 2016 tourism continues to be the largest revenue earner and employer in Fiji and the industry
675,050 660,590 657,706 691,630 754,655 792,320 thereby creates a multiplier effect in the local economy supporting business.

This activity and livelihoods supports people working in many other industries such as
800000
food & beverage and transport. The target by Tourism Fiji is 1,000,000 visitors and a
$2.2B industry by 2021.

Tourism earnings (FJ$) by year

700000 2011 2012 2013 2014 2015 2016
675,050 660,590 657,706 691,630 754,655 792,320

600000
2011 2012 2013 2014 2015 2016 1700

1600

65% of arrivals come from New Zealand and Australia being the near neighbours to Fiji 1500
with a flying time of three and four hours respectively.
1400

This demonstrates that the strength of the market is dominated from New Zealand and 1300
Australia. We have seen further growth from the Asian market and in particular China
1200
where compound average growth is over 40%. We believe this will be consolidated
and perhaps expanded given more frequent flights from mainland China and Asia. 1100
Further the United States continues to show an increasing proportion of arrivals with a 1000
compound average growth of approximately 5%. 2012 2013 2014 2015 2016
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Target Market
The Fiji hospitality market has demonstrated increasing confidence. In particular, with The successful purchaser could come from anywhere within our global reach. We
the upgrade of the Pearl Resort, the Starwoods acquisition, rebranding of the Amunuca believe the most likely eventual buyer will be an experienced and well-funded developer
on Tokoriki Island to a Sheraton and the upgrade of the Yalulele Resort, Natadola. or individual.

There is the development of the Marriott (Momi Bay) which opened in April 2017. We are aware of a number of Chinese, Korean, New Zealand, Australian and European
investors that are looking closely at the potential of Fiji. With the assistance of our
In addition, increasing arrivals from generating markets, particularly from New Zealand global network, we are able to generate interest from developers, investors and private
and Australia all underpin the tourism economy within Fiji. individuals from around the world.

A new proposal to South Denarau (Denarau Waters) with a marina, hotels, canal front There are many opportunities for tourism and residential investors with another key
residential and commercial all reinforces the confidence in the Fiji market. potential market being “private individuals”.

In fact, 100 residential lots were sold over a 10 month period in Denarau Waters. We believe the property may well appeal to a high net worth individual as a private
retreat and they would be seeking to secure premises for the long term.
Additional Hotel Development Sites:
Alternatively a purchaser may consider developing a resort and branding under an
• Port Denarau proposed hotel Denarau Yacht Club area exclusive luxury brand.
• Port Denarau hotel site adjacent to the carpark in the commercial area
• Due diligence on a hotel in Denarau Waters Purchasers which could have an interest in the property for investment or operate as an
• Completion of the Pullman Wailoaloa owner occupier could include:
• Proposed Holiday Inn, Denarau Island (152 keys)
• Possible Sofitel SO, Momi Bay, 5 star by CP Group • Hotel and leisure
• Due diligence on a hotel on Naisoso Island • Investors in tourism
• Private individual
This strengthens confidence in Fiji. New Zealand and Australia have shown strong
increases in tourist arrivals and this has flow on effects for improved investor
confidence.
15 Knight Frank.co.nz

Method of Sale & Disclaimer

The method of sale is by way of a Private Treaty process or Expression of Interest The information contained in the Information Memorandum is published by Knight
Frank for the vendor solely for potential purchasers to assist them in deciding
Initial investigations will allow for due diligence subject to the signing of a whether or not they wish to make further enquiries with respect to the property.
confidentiality agreement. All interested parties will be consulted and urged to Any depictions of property boundaries are approximate. In common with all
conduct their own due diligence and make their best offer. owners of land in Fiji the vendor does not have any ownership or exclusive rights
of the adjoining sea, beaches, foreshore, rivers or streams. None of the information
The conclusion of the sale period will be 180 days from the commencement date. contained in this report can constitute any representation or offer by the vendor
or the Agent. Prospective purchasers and their advisors should make their own
With the ability to upgrade and redevelop the resort, there is the potential for a enquiries to satisfy themselves as to the correctness of the information.
further subdivision for a private residential development.
The Agent will not assume liability for negligence or otherwise for the material
The overall landscape allows for a full development of tourism ideas in order to contained in this report. Any liability on the part of the Agent, its employees or
expand the existing property. agents for loss or damage in any claim arising out of or in connection with this
memorandum (other than liability which is totally excluded by this clause), shall
All offers will be confidential and with the ability by way of private treaty, there is not (whether or not the liability results from or involves negligence) exceed $1,000.
the ability to negotiate with perspective buyers. This will provide a fair process for
buyers to understand the property and ultimately achieve a realistic pricing. Value Added Tax Disclaimer
The purchase price and the value of the property may be affected by Value Added
Further, given that the property offers a freehold tenure, this is considered of high Tax (VAT). Knight Frank is not qualified to provide advice on any VAT issue relating
value as in fact only 8% of the total land area in Fiji is freehold. to the property including how the purchase should be structured to comply with
VAT legislation in Fiji.

You should satisfy yourself by your own enquiries as to the impact of VAT upon
the purchase price. Neither the Vendor nor Knight Frank makes any representation,
express or implied, as to whether or not VAT has any effect on the property or the
purchase price.

KFNZ Ltd, LA (REAA 2008), MREINZ

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Fiji
Tax and Customs
Incentives

2016 / 2017
Fiji Tax and Customs Incentives 2016 / 2017

Table of Contents

Page No.

Tax Rate Reduction 4

2016 – 2017 Investment Package 5
Hotel Investment Incentives 5
Film Making and Audio Visual Incentives 6
Agriculture Incentives 7
Small and Micro Enterprises (Sme’s) 7
Tax Free Region Incentives 7
Information Communication Technology (Ict)
8
Incentives
Manufacturers Incentives 8
Shipping Companies 8
Unit Trust Companies 8
Fiji My Second Home Programme 8
Foreign Currency Account Scheme 9
Medical Investment Incentives 9
Electric Vehicles Charging Stations 9
Residential Housing Development Incentives 9
Other Incentives 10
Other Customs Concessions 10
Tax Free Region Fiji Map 11
Our Vision (Where we want to be):
A world class revenue authority delivering excellence in revenue
collection, border protection, trade and travel facilitation.

Our Mission (Our purpose and role):

Helping Fiji Grow as a leading contributor and funder of sustainable
economic, security and social initiatives.

Our Values:
One Organisation:
We will all work as one toward the goals of FRCA displaying teamwork
and respect for each other.

Leadership:
We will set direction and create a customer orientation, clear and visible
values and high expectations. The leaders will ensure the creation of
strategies, systems, and methods of achieving excellence and building
knowledge and capabilities.

Results Focus:
Our performance measurements will focus on key results. Results
should be guided by and balanced by the interest of all stakeholders
that includes Government, taxpayers and intermediaries. The use of
a balanced set of performance measures offers an effective means Partnership and Engagement:
to monitor actual performance, and to marshal support for improving We build internal and external partnerships to better accomplish our
results. goals.

Continuous Improvement and Learning: Valuing Employees:

Achieving the highest level of performance requires a well-executed Our success depends increasingly on the knowledge, skills and
approach to continuous learning and improvement. The term “continuous motivation of our workforce. We will invest in the development of our
learning” means incremental and breakthrough improvement. The term” workforce through education, training, welfare and giving opportunities
learning” refers to adaptation to change, leading to new goals and or/or for their continual growth. In return FRCA has the right to expect high
approaches. levels of productivity and integrity from its employees.

Design Quality and Prevention:

We will emphasize design quality – problems and waste prevention at
the design stage are less costly than correcting problems that happen
“downstream.”

3
Fiji Tax and Customs Incentives 2016 / 2017

TAX RATE REDUCTION

• A foreign company that establishes/relocates its Headquarters to

YEAR RESIDENT NON-RESIDENT
Fiji will be subject to a low corporate tax rate of 17%.
• A 150% tax deduction is available for capital expenditure incurred COMPANIES COMPANIES
for the set-up of the Headquarters relocation to Fiji 2001 From 35% to 34% From 45% to 34%
• A listed company on the South Pacific Stock Exchange (SPSE) will 2002 From 34% to 32% From 34% to 32%
be subject to a low corporate tax rate of 10%.
2003 No change – 32% No change – 32%
• A 150% tax deduction is available for expenses incurred by
companies carrying out restructure and reorganization for the 2004 From 32% to 31% From 32% to 31%
purpose of listing on SPSE, on the condition that the company gets 2005 - 2008 No Change – 31% No Change – 31%
to list on SPSE within 24 months after the company commences 2009 From 31% to 29% From 31% to 29%
with the restructure and reorganization.
2010 From 29% to 28% From 29% to 28%
• Income earned from trading of shares in SPSE will be exempted
from Income Tax and Capital Gains Tax. 2011 28% 28%
2012 From 28% to 20% From 28% to 20%
2013-2017 (July) 20% 20%

RESIDENT TAXPAYERS: 2017 (July) NON-RESIDENT TAXPAYERS: 2017 (July)

Chargeable Income ($) PAYE Tax Payable ($) Social Responsibility Chargeable Income ($) PAYE Tax Payable ($) Social Responsibility
Tax (SRT) Payable Tax (SRT) Payable
0-16,000 20% of excess of $0
0-16,000 Nil 16,001 – 22,000 3,200 + 20% of excess
16,001 – 22,000 7% of excess over over 16,000
$16,000 22,001– 50,000 4,400 + 20% of excess
22,001– 50,000 420 +18% of excess over $22,000
over $22,000 50,001 – 270,000 10,000 + 20% of
50,001 – 270,000 5,460 +20% of excess excess over $50,000
over $50,000 270,001 - 300,000 54,000 +20% of 23% of excess over
270,001 - 300,000 49,460 + 20% of 23% of excess over excess over $270,000 $270,000
excess over $270,000 $270,000 300,001 - 350,000 60,000 + 20% of 6,900 + 24% of excess
300,001 - 350,000 55,460 +20% of excess 6,900 + 24% of excess excess over $300,000 over $300,000
over $300,000 over $300,000 350,001 - 400,000 70,000 + 20% of 18,900 + 25% of
350,001 - 400,000 65,460 + 20% of 18,900 + 25% of excess over $350,000 excess over $350,000
excess over $350,000 excess over $350,000 400,001 - 450,000 80,000 + 20% of 31,400 + 26% of
400,001 - 450,000 75,460 + 20% of 31,400 + 26% of excess over $400,000 excess over $400,000
excess over $400,000 excess over $400,000 450,001 – 500,000 90,000 + 20% of 44,400 + 27% of
450,001 – 500,000 85,460 + 20% of 44,400 + 27% of excess over $450,000 excess over $450,000
excess over $450,000 excess over $450,000 500, 001 – 1,000,000 100,000 + 20% of 57,900 + 28% of
500, 001 – 1,000,000 95,460 + 20% of 57,900 + 28% of excess over $500,000 excess over $500,000
excess over $500,000 excess over $500,000 1,000,001 + 200,000 + 20% 197,900 + 29%
1,000,001 + 195,460 + 20% 197,900 + 29% of excess over of excess over
of excess over of excess over $1,000,000 $1,000,000
$1,000,000 $1,000,000

4
 2016 – 2017 INVESTMENT HOTEL INVESTMENT
PACKAGE INCENTIVES
INVESTMENT ALLOWANCE STANDARD ALLOWANCE
• Investment allowance (excluding cost of labor) of 40% for • Investment allowance (in addition to ordinary depreciation) of 25%
extension and renovation expenses with a minimum qualifying of total capital expenditure is allowed as a deduction provided there
capital expenditure of $50,000. This is only available to existing is no shift of tax revenue to other countries.
businesses in Vanua Levu. • Applicable to building of new hotel including renovations or
refurbishments or extensions of existing hotel and International
ACCELERATED DEPRECIATION Retiree Facilities.
• Accelerated depreciation for building erected before 2001 has • Investment Allowance can only be written-off against the income of
been extended to 2018. 20% depreciation for building used for the hotel business or income from the hotel premises.
agricultural, commercial or industrial purpose can be written off • Losses carried forward extended to 4 years.
within any 5 of 8 years. • Recipients of the provisional approval for Standard Allowance in
• 100% write off will be available in the year the expenditure was 2016 shall complete the project within two years from the date the
incurred on water storage facilities and renewable energy plant and provisional approval was granted
machineries. • Investors would only need to provide a sketch plan to obtain
• This will also be available to new plants and machineries used for provisional approval for the investment allowance, and not
manufacturing purposes. necessarily a certified approved.
• There will be no Investment Allowance from 2017 for existing
EXPORT INCOME DEDUCTION hotels.
• “Export income” means net profits derived by a taxpayer from the
business of exporting goods and services but excludes re-exports. NEW SHORT LIFE INVESTMENT PACKAGE
Deduction shown below. • 10 year tax holiday for capital investments not less than $7million.
• Import duty exemption on all capital goods (including capital
equipment, plant & machinery) not available in Fiji but this does not
Year of assessment Percentage of export income to
include furniture or motor vehicles that are used in carrying out the
be deducted
investment.
2011 50% • Short Life Investment Package (SLIP) Incentives is also available
2012 40% for retirement facilities and hospital resorts.
• Short Life Investment Package (SLIP) Incentives is also available
2013 40% for NEW Apartments provided the length of stay is not more than 6
2014 40% months.
• Recipients of the provisional approval for SLIP in 2016 shall
2015 50%
complete the project within two years from the date the provisional
2016/2017 50% approval was granted.
• Investors would only need to provide a sketch plan to obtain
• Export income deduction will only be allowed if the Commissioner provisional approval for the investment allowance, and not
of Inland Revenue is satisfied that the export earnings will be necessarily a certified approved.
remitted to Fiji. • There will be no SLIP from 2017 for existing hotels.
• A new SLIP incentive with 4 years Tax holiday will be available to
LOSS CARRIED FORWARD new hotels from 2017. This SLIP incentive will not be available to
• Loss carried forward can be claimed up to 4 years. Loss carried renovations
forward by a company is allowed if that entity satisfies the
continuity of ownership test or the same business test. BACKPACKER OPERATIONS
• Income tax exemptions will be introduced for locally owned
DUTY CONCESSIONS backpacker operators with annual sales turnover of $1m or less.
PRODUCTION INPUTS • Duty exemption on the importation of raw materials and equipment
• All goods used as raw materials in the manufacture of approved used for the establishment of a backpacker hotel. (This incentive
goods not available locally will attract 0% fiscal duty + 9% VAT. will only be available to backpacker businesses who are granted the
income tax holiday).
CAPITAL ITEMS
• Duty rates on capital items (which refer to machinery used for
converting / processing raw materials) will attract 0% fiscal duty +
9% VAT.

5
Fiji Tax and Customs Incentives 2016 / 2017

FILM MAKING AND AUDIO VISUAL INCENTIVES

INCOME TAX DEDUCTIONS Additional Incentives (Allowable Expenditures):

• 150% deduction for capital expenditure on an F1 audio-visual • Allowable expenditure incurred for services rendered by the produc-
production. ers (producer’s fees) – provided that such expenditure shall not ex-
• 125% deduction for capital expenditure on an F2 audio-visual ceed 10% of the total Fiji Expenditure. Producers are not restricted
production. to remain in Fiji throughout the production of the film.
• 75% of the expenditure incurred to purchase costumes, make-up
Levels of Expenditure in Fiji for an audio-visual production for F1 and F2 and set design properties not available in Fiji that will be used in
status should not be less than: relation to the film production in Fiji provided that any such cos-
• 40% for a large format film, a feature film or broadcast television tumes, make-up and set design properties shall be left in Fiji at the
programmes; end of the production.
• 50% for a direct to video programme or video disk programme; and • Expenditure incurred to purchase the writer’s story and rights for
• 55% for an audio recording. the production of the film provided that the producer submits the
following documentary evidence:
INCOME TAX EXEMPTIONS o Notarized legal contract with the writer which is registered in Fiji
• Net income from an F1 production is exempt until taxpayer has with the Registrar of Deeds upon payment of the appropriate stamp
received a 60% return on capital expended. Thereafter, net income duty;
will be fully taxed at the marginal rate. o Evidence of payment made directly into the writer’s bank account
from the Fiji bank account; and
• Net income from an F2 production is exempt until taxpayer has o Receipt of acknowledgement of payment received.
received a 50% return on capital expended. Thereafter, net income • Approved post-production expenditure on the film paid from a Fiji
will be fully taxed at the marginal rate. bank account to the extent that it is incurred or reasonably at-
tributable to approved post-production services in relation to the
STUDIO CITY ZONE CONCESSIONS completing of the film made in Fiji. The maximum payable in rebate
• Any sole proprietor, partnership or company that carries on a shall be granted upond the production of documentary evidence of
production activity (the production of, distribution of or supply of the expenditure. Rebate is around 2%-2.5% of production budget.
services to audio-visual productions) may qualify for an operating • Expenditures incurred on hiring of cameras and filming equipment
licence in the Studio City Zone and be entitled to an exemption from outside Fiji, where such cameras and filming equipment are
from tax on the income from the production activity carried on in not available in Fiji.
the Zone.
• Tax free status for “permanent residents” of the Studio City Zone on Additional Requirements:
income derived as earnings from audio-visual productions. • Companies should engage Audio Visual Agents
• For residence in the Zone to be approved, in the case of citizens, the • Fiji as a location needs to be accredited and acknowledged in the
individual must be: film’s credits and other accreditation as stipulated by Film Fiji in
• resident in the Zone for at least 183 days; their approval letter.
• have pre-tax audio visual earnings in excess of $100,000;
• have fixed assets in the Zone in excess of $250,000; and
• maintain a primary place of residence in the Studio City Zone.
• For residence in the Zone to be approved, in the case of non-citizens
(or a citizen who derives a minimum of 80% of audio visual earnings
from outside Fiji), the individual must be: -
• resident in the Zone for at least 60 days;
• have pre-tax audio visual earnings in excess of $100,000;
• have fixed assets in the Zone in excess of $250,000; and
• maintain a permanent place of residence in the Studio City Zone.

FILM TAX REBATE

Summary Part 5 - Income Tax (Film-making and Audio-visual Incentives) Regulations 2016

Fiji Film Tax Rebate Bill

Rebate Amount 47% tax rebate or credit on production costs spent in Fiji: paragraph 69(1)

Eligibility Films and television productions, as per the Income Tax (Film-making and Audio-visual Incentives) Regulations
2016 : paragraph 70

Minimum Spend in country Minimum spend in Fiji F$250,000 for feature films and broadcast television; and $50,000 for production intended
as an advertising program or commercial in at least one significant international market : paragraph 70(e)

Maximum F$28.2 million, so even if more than $60 million spent in Fiji the maximum rebate is still F$28.2 million: paragraph
Rebate 69 (2).

Exclusions Where a producer has chosen to access the film tax rebate, the producer will not be able to obtain any other
tax concessions under Parts 5 of the Income Tax (Film-making and Audio-visual Incentives) Regulations 2016:
paragraph 68(2).

6
 AGRICULTURE INCENTIVES SMALL AND MICRO
ENTERPRISES (SME’S)
Commercial Agriculture and Agro-Processing Income tax exemption to be applicable to selected sectors with
• The income of any new activity in commercial agricultural farming maximum turnover threshold of $500,000. The sectors include:
and agro-processing approved and established from 1 January • Agriculture and Fishing (For Agriculture, this will cover activities in
2015 to 31 December 2018 shall be exempt from tax as follows: the entire Agriculture Sector).
• capital investment from $250,000 to $1,000,000, for a period 5 • Tourism (Sea Cruise and River tour Operators).
consecutive fiscal years; or • Community and Social Services (Amusement, recreation services;
• capital investment from $1,000,000 to $2,000,000, for a period traditional handicraft producers (not “middleman” or agents).
of 7 consecutive fiscal years; or • Supportive projects to tourism industry (flora, fauna and other
• capital investment above $2,000,000 for a period of 13 natural characteristics of Fiji; and history, traditions, cultures and
consecutive fiscal years. ways of life of its peoples).

Bio – Fuel Production

• 10 year tax holiday is available to a taxpayer undertaking a new
activity in processing agricultural commodities into bio-fuels
as approved by the Commissioner from 1 January 2009 to 31
December 2018. To qualify, the taxpayer must have:-
• Minimum level of investment of $1,000,000; and
• Employ 20 local employees or more for every income year.
• Duty free importation of plant, machinery and equipment for initial
establishment of the factory.
• Duty free importation of chemical required for bio-fuel production.
• The Importation of all agricultural items will be subject to zero Duty.

>> See Tax Free Region Map on Page 11

TAX FREE REGION INCENTIVES

Who will qualify for this incentive? the Rewa Bridge excluding the town boundary of Nausori, up
• This incentive is available to a newly incorporated entity engaged to the Ba side of the Matawalu River shall be exempt from tax
in a new business established in the following areas:- Vanua Levu as follows:
(including Taveuni, Rabi, Kioa and other islands generally included • capital investment from $250,000 to $1,000,000, for a
for government’s administrative purpose as being in the Northern period 5 consecutive fiscal years; or
Division); Rotuma; Kadavu; Levuka; Lomaiviti; Lau: and Nausori- • capital investment from $1,000,000 to $2,000,000, for a
Lautoka region (from Nausori Airport side of the Rewa River (ex- period of 7 consecutive fiscal years; or
cluding township boundary) to the Ba side of the Matawalu River. • capital investment above $2,000,000 for a period of 13
• Any company may apply to the Minister for Finance in a prescribed consecutive fiscal years.
form for an operating licence.
Duty Exemption
Criteria for Grant of Licence Import duty exemption on the importation of raw materials, machinery
• The company is a newly incorporated entity engaged in a new and equipment (including parts and materials) insofar as they are
business. required for the establishment of the business in the Tax Free Region.
• The minimum initial level of investment should be $250,000
Other benefits under the TFR
Tax Exemptions Available • Additional 5 years of income tax exemption is available to any
• The income of any new activity approved and established between company granted a license and having indigenous Fijian landown-
(i) 1 January 2009 to 31 December 2018 for Vanua Levu, Ro- er equity of at least 25 percent.
tuma, Kadavu, Levuka, Lomaiviti & Lau • Additional 7 years of income tax exemption is available to any
(ii) 1 January 2014 to 31 December 2018 for East of Vitilevu hotel developer granted a license and having indigenous Fijian
(Korovou to Tavua region) landowner equity of at least 25 percent.
(iii) 1 January 2016 to 31 December 2018 from the airport side of

7
Fiji Tax and Customs Incentives 2016 / 2017

INFORMATION MANUFACTURERS INCENTIVES

COMMUNICATION
TECHNOLOGY(ICT) INCENTIVES Food Processing & Forestry
• 100% of the amount of investment as a deduction for investing
(i) The income of an Income Communication Technology (ICT) in food processing as well as forestry. Re-investment will also be
operator operating in the declared Kalabu Tax Free Zone from 1 allowed for expansion purposes. In order to qualify, the investor
January 2007 to 31 December 2016 shall be exempt from tax for 10 should utilize 50% of local produce in its production process.
years.
• Income tax exemption is available to ICT investors under the Renewable Energy Projects and Power Cogeneration
following criteria:- • 5 year tax holiday is available to a taxpayer undertaking a new
• Business employs 50 employees or more for any 6 months activity in renewable energy projects and power cogeneration as
within the income year; and approved by the Commissioner.
• 60 percent of its total services is exported. • Duty free importation of renewable energy goods is also available.

(ii) The income of any new operator who is granted a license from 1
January 2009 to be exempt from tax for a period of 13 years
• Any new operator may apply and pay a license fee of $1,000
per annum to the Commissioner of Inland Revenue. The Tax
exemption is granted from the date of the initial license.
• Income tax exemption is available to investors under the SHIPPING COMPANIES
following criteria:-
• Business employs 50 employees or more for any 6 months
within the income year; and
• 60 percent of its total services is exported. Maritime Shipping
• Duty free importation of computer, computer parts & • A 7 years tax holiday will be introduced for shipping companies
accessories, plant, equipment & fittings, and specilised servicing uneconomical routes, which includes Rotuma and Lau.
furniture for initial establishment and during its ongoing The uneconomical routes will be ring-fenced.
operations to approved ICT/BOP Business operators from 1 • All importation of spare parts for Maritime vessels will be subject to
January 2009. zero duty.

ICT Accredited Training Institutions

The income of any new operator setting up internationally accredited
ICT training institutions who is granted a license from 1 January 2015 to
be exempt from tax for a period of 13 years
• Any new operator may apply and pay a license fee of $1,000 per
annum to the Commissioner of Inland Revenue. The Tax exemption UNIT TRUST COMPANIES
is granted from the date of the initial license.
• Income tax exemption is available to investors under the following
criteria:-
Withholding Tax and Capital Gains Tax Waiver
• Business employs 50 employees or more for any 6 months
• Withholding taxes and capital gains taxes on interest income
within the income year; and
distribution to investors of the Unit Trusts will be waived.
• 60 percent of its total services is exported.
• Duty free and VAT exemption on the importation of all items
required for the establishment of the business.

Application Design and Software Development

The income of any new operator setting up ICT businesses involved
in Application designing and Software development who is granted a
license from 1 January 2015 to be exempt from tax for a period of 13 FIJI MY SECOND HOME
years
• Any new operator may apply and pay a license fee of $1,000 per PROGRAMME
annum to the Commissioner of Inland Revenue. The Tax exemption
is granted from the date of the initial license. • This Programme is open to citizens of other countries recognized
• Income tax exemption is available to investors under the following by Fiji in the “Fiji My Second Home Programme” as administered by
criteria:- the Reserve Bank of Fiji.
• Business employs 50 employees or more for any 6 months • Interest income is exempt from tax under the following criteria:-
within the income year; and • Age below 50 years old:
• 60 percent of its total services is exported. • Minimum deposit of $150,000 and maintain the deposit in
• Duty free and VAT exemption on the importation of all items Fiji for a minimum of two years.
required for the establishment of the business. • Age 50 years and above:
• Minimum deposit of $100,000 and maintain the deposit in
Small ICT start-ups
Fiji for a minimum of two years.
• For small ICT start-ups, a 150% deduction on all start-up costs will
• To qualify the applicant must maintain a minimum balance of
be made available with no employment conditions/requirements
$50,000 from the third year onwards and throughout the entire stay
attached.
in Fiji.

8
 FOREIGN CURRENCY ELECTRIC VEHICLES
ACCOUNT SCHEME CHARGING STATIONS
• Interest income is exempt from tax which accrues to or in favor of • The income of any business setting up Electric Vehicle Charging
a non-resident including former Fiji residents who hold funds in Fiji Stations on or after 1st August 2016:
commercial bank accounts under the following criteria:- • Shall be exempt from tax for a period of 7 years provided that the
• For foreign currency accounts, interest income for deposit minimum capital expenditure is $3,000,000.
above the equivalent of FJD$150,000; • Shall be granted a subsidy up to a maximum of :
• For Fiji Dollar accounts, any amount of interest income. • 5% of the total capital outlay incurred in the development of
electric vehicle charging stations provided that the capital
investment level is not less than $3,000,000 and not more than
$10,000,000.
• 7% of the total capital outlay incurred in the development of
electric vehicle charging stations provided that the capital
expenditure is not less than $10,000,000.
MEDICAL INVESTMENT • Loss carried forward of 8 years;
• Duty concessions on all capital goods imported will apply.
INCENTIVES
i. The income of any business setting up Private Hospitals on or after
1 January 2016:
• Shall be exempt from tax for a period of 10 years provided that
the minimum capital investment level is $7,000,000
• 60% Investment Allowance will apply for refurbishments,
RESIDENTIAL HOUSING
renovations and extensions with a minimum capital investment
of $1,000,000 DEVELOPMENT INCENTIVES
• Duty Concession (Free Fiscal Duty, Free Import Excise & Free
VAT) on medical, hospital, surgical, dental goods that are used (i) This Incentive is available to companies with:
and imported by the business. • capital investment (including the cost of support infrastructure
• Recipients of the provisional approval for setting up Private and overseas consultant fees but excluding the cost of land)
Hospitals shall complete the project within two years from the over $2,000,000 with at least 20 residential housing units; and
date the provisional approval was granted • the project commences on or after 1 January 2016 and
• Loss carried forward of 8 years the building is completed within 2 years from the date the
ii. The income of any business setting up Ancillary Medical Services provisional approval was granted.
such as Pathology Lab, MRI, other diagnostics on or after 1 January (ii) Provisional approval is granted after the Minister consults the
2016: Minister responsible for Housing.
• Shall be exempt from tax for a period of 4 years provided that (iii) The income of the company:
the minimum capital investment level is $2,000,000 • shall be exempt from tax on developer profits from the sale of
• 60% Investment Allowance will apply for refurbishments, residential units
renovations and extensions with a minimum capital investment • shall be granted a subsidy up to a maximum rate of:-
of $500,000 • 5% of the total capital expenditure incurred in the
• Duty Concession (Free Fiscal Duty, Free Import Excise & Free residential housing development provided that the capital
VAT) on medical, hospital, surgical, dental goods that are used expenditure is not less than $2,000,000 and not more than
and imported by the business. $10,000,000: and
• Recipients of the provisional approval for setting up Ancillary • 7% of the total capital expenditure incurred in the
Medical Services shall complete the project within two years residential housing development provided that the capital
from the date the provisional approval was granted expenditure is more than $10,000,000.
• Loss carried forward of 8 years (iv) Duty concession on all capital goods imported will apply.

9
Fiji Tax and Customs Incentives 2016 / 2017

OTHER INCENTIVES

Employment Taxation Scheme Donation of new Computers, Laptops & Tablets

First time employees • 150% and 200% tax deductions for donation of computers to
• A person carrying on business in Fiji is allowed a 200% deduction schools registered with the Ministry of Education, will be available
for the amount of any salary or wages paid to a qualifying em- with the following features:
ployee between 1 August 2016 and 31 December 2020, provided • 200% tax deduction relates to donation to schools in rural areas.
that the salary or wages paid to the qualifying employee in respect • 150% tax deduction relates to donation to schools in urban areas
of whom the deduction is claimed must not be less than the mini- • Donations to be between $10,000 to $100,000.
mum wage prescribed by written law for a particular industry or
sector. Voluntary Contribution for Disaster Relief
Work placements A 150% tax deduction for voluntary contribution of cash donation by
• A person is allowed a deduction for 200% of the amount of any businesses towards a Disaster Relief Fund was introduced in 1 January
salary or wages paid to a student for employment of the student 2014. The threshold will range from a minimum contribution of $10,000
for a period not exceeding 6 months in a 12-month period before to a maximum contribution of $100,000.
the student’s graduation where the employment forms part of the
student’s course requirements of a higher education institution as Sports Sponsorship
defined in the Higher Education Promulgation 2008. The deduction A 150% tax deduction is available for cash sponsorship made to the
is available and can be claimed between 1 August 2016 and 31 Sports Fund. The minimum threshold for contribution is $50,000.
December 2020.
Part-time workers Sponsorship of hiring of international Coaches
• A person is allowed a deduction for 200% of the amount of any sal- A 150% tax deduction was introduced in 2014 for sponsorship between
ary or wages paid to a student for employment of the student in an $100,000 and $200,000 towards the hiring of international sporting
area related to the student’s area of study for a period not exceed- coaches.
ing 3 months in a 12-month period. The deduction is available and
can be claimed between 1 August 2016 and 31 December 2020. Cash Contribution towards Housing Projects
Persons with disabilities A 150% tax deduction was introduced in 2014 for cash contributions
• A person is allowed a deduction for 300% of the amount of any up to $50,000 towards any Government sanctioned housing project for
salary or wages paid to a person with a disability for a consecu- squatters and informal settlements.
tive period of 3 years, provided that if the employee is unfairly
dismissed, any deduction allowed must be recouped by the CEO. Voluntary Contribution for Disaster Relief for FARMERS
The deduction is available and can be claimed between 1 August A 200% tax deduction for voluntary contribution of cash donation by
2016 and 31 December 2022. taxpayers towards a Farmers Emergency Fund Account for disaster
Employee development relief was introduced on 1 January 2015. The minimum threshold for
• A person is allowed a deduction for 150% of the amount paid by contribution is $10,000.
the person for an employee’s education fees to study during the
course of the employee’s employment, provided that the employee Tax Deduction on Fijian Made Uniforms
is required to work for the person for a minimum of one year upon Annual tax deduction of 50% is available for the value of Fijian made
the completion of the employee’s study. uniforms supplied by businesses to their staff

OTHER CUSTOMS CONCESSIONS

Newly introduced concessions Other existing concessions

Items Descriptions Fiscal (%) VAT (%) Items Descriptions Fiscal VAT
(%)
Modems All modem 0% 9%
Agriculture & Specialised agriculture, livestock Free 9%
types
Dairy and dairy machineries, equipment
Optic Fibre 0% 9% and agricultural inputs excluding
Cables those that attract duty rates of
free Fiscal and free Import Excise
Dress Patterns 0% 9% in the Tariff. The importation
under concession is subject
to the condition that a letter of
approval is issued by the Ministry
of Agriculture in relation to goods
under concession.

10
 OTHER CUSTOMS CONCESSIONS (continued)

Items Descriptions Fiscal VAT Items Descriptions Fiscal VAT

(%) (%)
Bus Operators Bus operators holding Road Service 2 Fisheries & Specialised machineries directly Free 9%
Licence operating under schedule cents Forestry used for fisheries and forestry
trips approved by Land Transport per purposes. The importation under
Authority. Refund of duty on gas litre concession is subject to the
oil (diesel) having sulphur content refund condition that a letter of approval is
not exceeding 500ppm purchased issued by Department of Fisheries
ex-duty paid stock. & Department of Forests in relation
to goods under concession.
Backpacker To promote locally owned Free 9%
Operators backpacker operations. Duty Fishing Industry Exemption of bunker fee 2cents/ Free 9%
exemption on the importation litre and duty free fuel concession
of raw materials and equipment for local fishing vessels. The
used for the establishment eligibility of this duty concession
of a backpacker hotel are not will be based on the fulfillment
manufactured and available in of the new eligibility criteria
Fiji (This will only be available to and approval by the Minister for
backpacker businesses who are Finance.
granted the income tax holiday).
Pre-fabricated (i)Pre-fabricated houses (kit homes) 3% 9%
houses (Kit
(ii) Pre-fabricated concrete 5% 9%
Homes)
products and iron panels for
commercial use

FIJI TAX FREE REGION MAP

- Tax Free Regions

11
 Fiji Revenue & Customs Authority
Head Quarters: Revenue & Customs Phone: (679) 324 3000
Services Complex Fax: (679) 331 5537
Private Mail Bag, Suva Email: [email protected]

www.frca.org.fj
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