Sovereign Verdict
EXCLUDED
Statutory ISIC
0141
Regulatory Activity Scope
Raising of cattle and buffaloes
"Under Ministerial Decision No. 229 of 2025, primary agricultural production (ISIC 0141) is not listed as a Qualifying Activity for Free Zone Persons. The biological transformation of livestock does not constitute 'Manufacturing' under the technical definitions of the Decree-Law. Consequently, income from the sale of cattle or buffaloes is treated as taxable income at the standard 9% rate, regardless of Free Zone status, unless it falls under the de minimis requirements."
Forensic Audit Red Flag
Attempting to reclassify biological growth and primary production as 'Manufacturing or Processing of Goods' to exploit the 0% Free Zone rate.
Statutory Authority
Article 3, Clause 1 of Ministerial Decision No. 229 of 2025
Nexus Requirement
Requires physical farm infrastructure and local municipal/environmental permits
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX