Sovereign Verdict
MIXED
Statutory ISIC
0111
Regulatory Activity Scope
Growing of cereals (except rice), leguminous crops and oil seeds
"ISIC 0111 pertains to primary production. Under the framework of Ministerial Decision No. 229 of 2025, income from growing crops is generally treated as Non-Qualifying Income unless the entity can prove the activity constitutes 'Processing of goods or materials' or the income stays within the De Minimis threshold (5% or AED 5M). Forensic auditors will scrutinize the 'substantial transformation' of the biological asset to determine if it meets the definition of manufacturing/processing."
Forensic Audit Red Flag
Mischaracterization of primary agricultural production as 'Processing of Goods' to exploit the 0% regime
Statutory Authority
Article 2, Clause 1(c) and Article 3 of Ministerial Decision No. 229 of 2025
Nexus Requirement
Physical land lease within a Designated Zone and industrial/agricultural license nexus
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX