Sovereign Verdict
EXCLUDED
Statutory ISIC
0130
Regulatory Activity Scope
Plant propagation
"ISIC 0130 pertains to primary agricultural production. Under the framework reinforced by Ministerial Decision No. 229 of 2025, primary production is not listed as a Qualifying Activity. Unless the propagation involves significant industrial-scale biotechnological transformation that qualifies as manufacturing, the income is treated as Non-Qualifying and subject to the 9% Corporate Tax rate if de minimis thresholds are exceeded."
Forensic Audit Red Flag
Attempting to reclassify biological growth and propagation as 'Manufacturing of goods or materials' to access the 0% Qualifying Income rate.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 2 (Excluded Activities)
Nexus Requirement
Physical nursery infrastructure must be located within a Designated Zone with a valid agricultural or commercial license.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX