Sovereign Verdict
EXCLUDED
Statutory ISIC
011
Regulatory Activity Scope
Growing of non-perennial crops
"Primary agricultural production is not listed as a Qualifying Activity under the standard Free Zone regime. Income derived from the sale of raw crops is generally treated as Non-Qualifying Income. Forensic focus remains on whether the entity attempts to recharacterize crop sales as 'Distribution of Goods' from a Designated Zone to avoid the 9% headline rate."
Forensic Audit Red Flag
Artificial separation of 'Growing' (Excluded) from 'Processing' (potentially Qualifying Manufacturing) to manipulate the 5% De Minimis threshold.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 3, Clause 1(a)
Nexus Requirement
Physical land tenure within a Designated Zone and environmental permit alignment
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX