Sovereign Verdict
EXCLUDED
Statutory ISIC
015
Regulatory Activity Scope
Mixed farming
"Mixed farming (ISIC 015) is categorized as primary production. Under the UAE Corporate Tax framework for Free Zone Persons, primary production is not listed as a 'Qualifying Activity'. Therefore, income derived from the sale of raw crops or livestock is treated as Non-Qualifying Income, subject to the 9% rate unless falling under the de minimis threshold."
Forensic Audit Red Flag
Artificial separation of 'Processing' activities from 'Primary Production' to exploit the 0% Manufacturing rate on raw agricultural output.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 2, Clause 4
Nexus Requirement
Physical agricultural land lease/title and MOCCAE operational permit
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX