Sovereign Verdict
EXCLUDED
Statutory ISIC
0115
Regulatory Activity Scope
Growing of tobacco
"Primary production (Agriculture) is not listed as a Qualifying Activity under the current Free Zone regime. Income from the growing of tobacco is treated as non-qualifying income, subject to the 9% corporate tax rate, as it fails the 'Qualifying Activity' test defined for Free Zone Persons."
Forensic Audit Red Flag
Attempting to reclassify primary agricultural 'growing' as 'manufacturing' or 'processing' to claim the 0% rate under Qualifying Activities.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 3, Clause 1(g)
Nexus Requirement
Physical agricultural land tenure within a Designated Zone and MOCCAE licensing
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX