Sovereign Verdict
EXCLUDED
Statutory ISIC
023
Regulatory Activity Scope
Gathering of non-wood forest products
"ISIC 023 pertains to primary production and extraction of natural resources. Under the UAE Corporate Tax framework for Qualifying Free Zone Persons, primary sector activities (agriculture, forestry, and extraction) are generally not listed as Qualifying Activities. Unless the activity is ancillary to a 'Qualifying Manufacturing' process or involves 'Distribution of Qualifying Commodities' on a recognized exchange, the income is subject to the standard 9% rate."
Forensic Audit Red Flag
Attempting to reclassify 'Gathering' (primary extraction) as 'Processing' or 'Distribution' to qualify for the 0% rate under the Qualifying Income regime.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 4 (Non-Qualifying Activities)
Nexus Requirement
Physical presence in a Designated Zone with a specific agricultural or environmental license issued by a Free Zone Authority.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX