Sovereign Verdict
EXCLUDED
Statutory ISIC
0125
Regulatory Activity Scope
Growing of other tree and bush fruits and nuts
"ISIC 0125 pertains to primary biological transformation. Under the framework of Ministerial Decision No. 229 of 2025, primary agricultural activities are not listed as 'Qualifying Activities'. Unless the produce undergoes 'Processing' (as defined in MD 139 of 2023) within a Designated Zone, the income is treated as taxable at the 9% rate. Forensic auditors will scrutinize the 'Mainland' source of income if the produce is sold to the domestic UAE market without a Qualifying Correspondent."
Forensic Audit Red Flag
Recharacterization of 'Primary Production' (Growing) as 'Processing of Goods' to illicitly claim the 0% Qualifying Income rate.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 3, Clause 2 (Excluded Activities)
Nexus Requirement
Physical land tenure within a Designated Zone and a valid agricultural/environmental permit from the relevant Free Zone Authority.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX