Sovereign Verdict
MIXED
Statutory ISIC
0162
Regulatory Activity Scope
Support activities for animal production
"Under Ministerial Decision No. 229 of 2025, support activities for animal production are treated as services. Income is Qualifying only if the recipient is a Free Zone Person (FZP) or if the activity falls under the 'De Minimis' threshold for non-FZP transactions. Forensic scrutiny will focus on the 'Beneficial Recipient' of the services to ensure no hidden Mainland nexus exists."
Forensic Audit Red Flag
Mischaracterization of service-based support (ISIC 0162) as 'Processing of Goods' (ISIC 10xx) to attempt to qualify for the 0% rate on Mainland-sourced income.
Statutory Authority
Article 3, Clause 1(g) and Article 5 of Ministerial Decision No. 229 of 2025
Nexus Requirement
Free Zone licensing required with physical performance of services within the zone boundaries.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX