Sovereign Verdict
EXCLUDED
Statutory ISIC
022
Regulatory Activity Scope
Logging
"Logging (ISIC 022) is classified as a primary extractive/production activity. Under Ministerial Decision No. 229 of 2025, it does not fall under the exhaustive list of 'Qualifying Activities'. Income derived from the sale of raw timber is considered 'Excluded Income' and is subject to the 9% Corporate Tax rate if the de minimis threshold is exceeded."
Forensic Audit Red Flag
Misclassification of logging as 'Manufacturing' (Qualifying Activity) to claim 0% rate when no substantial transformation of the raw material occurs.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 3, Clause 1(g)
Nexus Requirement
Physical forestation or timber processing site must be located within a designated Free Zone with valid environmental permits.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX