Sovereign Verdict
EXCLUDED
Statutory ISIC
012
Regulatory Activity Scope
Growing of perennial crops
"ISIC 012 pertains to primary production. Under the UAE Corporate Tax regime for Free Zone Persons, primary industries (agriculture, mining) are generally excluded from 'Qualifying Activities' unless specifically listed. Income from the sale of perennial crops is treated as Non-Qualifying Income, subject to the 9% rate if it exceeds the de minimis threshold or if the entity fails to meet QFZP criteria."
Forensic Audit Red Flag
Attempting to reclassify primary agricultural production (Growing) as 'Processing of Goods or Materials' to benefit from the 0% Qualifying Income rate.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 4, Clause 2 (Excluded Activities)
Nexus Requirement
Physical land lease within a Designated Zone and specific environmental/agricultural permits from the Ministry of Climate Change and Environment (MOCCAE).
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX