Sovereign Verdict
EXCLUDED
Statutory ISIC
016
Regulatory Activity Scope
Support activities to agriculture and post-harvest crop activities
"ISIC 016 is classified as a service-based support activity. Under Ministerial Decision No. 229 of 2025, agricultural services are not listed as a 'Qualifying Activity'. Therefore, income derived from these services is treated as 'Non-Qualifying Income' taxable at 9% if it exceeds the de minimis threshold, or if provided to mainland persons."
Forensic Audit Red Flag
Mischaracterizing 'Post-harvest crop activities' (ISIC 0163) as 'Manufacturing/Processing' to illicitly claim 0% Qualifying Income status.
Statutory Authority
Article 3, Clause 1 (Excluded Activities) of Ministerial Decision No. 229 of 2025
Nexus Requirement
Physical performance of services must occur within a Designated Zone to avoid 9% Mainland attribution
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX