Sovereign Verdict
EXCLUDED
Statutory ISIC
0124
Regulatory Activity Scope
Growing of pome fruits and stone fruits
"Primary production (ISIC 0124) is not defined as a Qualifying Activity. Income from the sale of pome and stone fruits is categorized as Non-Qualifying Income. Under the QFZP regime, if this income exceeds the de minimis threshold (the lower of 5% of total revenue or AED 5,000,000), the entity loses its Qualifying status for the relevant tax period. Forensic focus is on the distinction between raw harvest sales and value-added manufacturing."
Forensic Audit Red Flag
Attempting to reclassify primary agricultural 'growing' as 'manufacturing' or 'processing' to qualify for the 0% rate under MD 265 of 2023.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 2; Cabinet Decision No. 100 of 2023, Article 3
Nexus Requirement
Physical agricultural land lease within a Free Zone and a specific agricultural activity license.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX