Sovereign Verdict
MIXED
Statutory ISIC
0161
Regulatory Activity Scope
Support activities for crop production
"ISIC 0161 is service-heavy and mobile. Under MD 229 of 2025, income is Qualifying only if the service is provided to a Qualifying Free Zone Person. If services are provided to mainland farmers, the income is Excluded. Forensic auditors will cross-reference GPS logs of agricultural equipment and work orders against the customer's trade license location to detect de minimis breaches."
Forensic Audit Red Flag
Mainland Service Leakage: Performing field preparation, harvesting, or pest control on mainland UAE farms while booking the revenue through a Free Zone entity to claim 0% tax.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 4, Clause 1(f)
Nexus Requirement
Physical presence of specialized agricultural machinery and technical staff within a Designated Zone; services must be rendered to other Free Zone Persons to qualify for the 0% rate.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX