Sovereign Verdict
EXCLUDED
Statutory ISIC
0121
Regulatory Activity Scope
Growing of grapes
"ISIC 0121 pertains to primary production. Under the framework established by Ministerial Decision No. 229 of 2025, primary agriculture is not categorized as a Qualifying Activity for Free Zone Persons. Consequently, income generated from the growing of grapes is treated as Excluded Income, subject to the standard 9% corporate tax rate regardless of the entity's location in a Free Zone."
Forensic Audit Red Flag
Artificial bundling of primary agricultural income with 'Processing of Food' to illicitly claim Qualifying Activity status under the 0% regime.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 3, Clause 2(g)
Nexus Requirement
Physical land title or agricultural leasehold and MOCCAE operational permit
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX