Sovereign Verdict
EXCLUDED
Statutory ISIC
0128
Regulatory Activity Scope
Growing of spices, aromatic, drug and pharmaceutical crops
"ISIC 0128 constitutes primary production. Under the framework of Ministerial Decision No. 229 of 2025, agricultural activities are not categorized as Qualifying Activities for Free Zone Persons. Therefore, income derived from the sale of raw crops is subject to the standard 9% rate. Forensic focus is on the strict separation of 'Growing' (Excluded) from 'Processing' (Qualifying Manufacturing) to prevent tax leakage."
Forensic Audit Red Flag
Recharacterization of primary crop cultivation as 'Manufacturing of Pharmaceutical Products' to illicitly access 0% Qualifying Income status.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 3, Clause 2
Nexus Requirement
Physical land tenure in UAE and MOCCAE agricultural licensing
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX