Sovereign Verdict
QUALIFYING
Statutory ISIC
0122
Regulatory Activity Scope
Growing of tropical and subtropical fruits
"Under the framework of MD 229 of 2025, the biological transformation of produce is categorized as a manufacturing/processing equivalent. To maintain QFZP status, the core income-generating activities (CIGA)—including planting, harvesting, and initial processing—must be physically performed within the Designated Zone. Income derived from the sale to mainland persons is only qualifying if the Designated Zone status is maintained and the 'Goods' criteria are met."
Forensic Audit Red Flag
Artificial inflation of 'growing' margins versus 'distribution' margins to shift profits from a non-qualifying mainland distributor to the qualifying producer.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 2, Clause 4
Nexus Requirement
Physical land title or leasehold interest within a Designated Zone and MoCCAE environmental compliance certification.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX