Sovereign Verdict
EXCLUDED
Statutory ISIC
0114
Regulatory Activity Scope
Growing of sugar cane
"Under Ministerial Decision No. 229 of 2025, primary production and extraction of natural resources (including agriculture) are categorized as Excluded Activities. Income derived from the 'Growing of sugar cane' is treated as non-qualifying income. If the entity is a Qualifying Free Zone Person, this income must be tested against the de minimis threshold; if exceeded, the entity loses its QFZP status for the period."
Forensic Audit Red Flag
Misclassification of primary agricultural production as 'Manufacturing or Processing of Goods' to attempt to qualify for the 0% rate under Qualifying Activities.
Statutory Authority
Article 3, Clause 1(i) of Ministerial Decision No. 229 of 2025
Nexus Requirement
Physical agricultural land lease within a Free Zone and specific environmental/agricultural licensing from the relevant Free Zone Authority.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX