Sovereign Verdict
QUALIFYING
Statutory ISIC
0126
Regulatory Activity Scope
Growing of oleaginous fruits
"Under MD 229 of 2025, the 'Growing of oleaginous fruits' is categorized under primary production and processing. To maintain Qualifying status, the Core Income-Generating Activities (CIGA)—including cultivation, irrigation, and harvesting—must be physically conducted within the Free Zone. Forensic audit will focus on the ratio of 'Land Area' to 'Yield' to ensure the entity is not acting as a mere conduit for mainland or imported produce."
Forensic Audit Red Flag
Reclassification of third-party sourced produce as 'own-grown' to exploit the 0% regime on non-qualifying trading income.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 2, Paragraph 4
Nexus Requirement
Physical agricultural land lease within a Designated Zone and MOCCAE operational permit.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX