Sovereign Verdict
EXCLUDED
Statutory ISIC
0112
Regulatory Activity Scope
Growing of rice
"ISIC 0112 pertains to primary production. Under the framework reinforced by Ministerial Decision No. 229 of 2025, primary agriculture is not an enumerated 'Qualifying Activity'. While 'Manufacturing and Processing' of goods is qualifying, the mere growing and harvesting of rice (primary sector) fails the activity test. Income derived from the sale of raw rice to the UAE mainland is subject to the 9% corporate tax rate."
Forensic Audit Red Flag
Misclassification of primary biological transformation (cultivation) as 'Manufacturing or Processing' to illicitly claim 0% tax rate.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 3, Clause 2 (Excluded Activities)
Nexus Requirement
Physical agricultural land tenure within a Designated Zone and MOCCAE environmental licensing.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX