Sovereign Verdict
EXCLUDED
Statutory ISIC
0123
Regulatory Activity Scope
Growing of citrus fruits
"ISIC 0123 pertains to primary production. Under the framework established by Ministerial Decision No. 229 of 2025, primary agricultural activities do not constitute 'Manufacturing or Processing of goods'. Therefore, income derived from the sale of raw citrus fruits is treated as taxable at the standard 9% rate, even if conducted by a Qualifying Free Zone Person, unless it meets the de minimis requirements."
Forensic Audit Red Flag
Artificial fragmentation of income where 'Growing' (Excluded) is bundled with 'Processing' (Qualifying) to mask non-eligible primary production revenue.
Statutory Authority
Article 3, Clause 1(g) of Ministerial Decision No. 229 of 2025
Nexus Requirement
Physical land lease within a Designated Zone and a specific agricultural permit from the Free Zone Authority
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX