Sovereign Verdict
EXCLUDED
Statutory ISIC
0230
Regulatory Activity Scope
Gathering of non-wood forest products
"ISIC 0230 covers primary extraction of biological resources. Under Ministerial Decision No. 229 of 2025, primary sector activities (forestry, gathering, and extraction) are not listed as Qualifying Activities for the 0% Corporate Tax rate for Free Zone Persons. Consequently, income from these activities is treated as taxable at the standard 9% rate, even if conducted by a Free Zone Person, as it fails the 'Qualifying Income' criteria."
Forensic Audit Red Flag
Attempting to re-classify 'Gathering' (Excluded) as 'Manufacturing of Food/Botanicals' (Qualifying) to claim the 0% Free Zone rate.
Statutory Authority
Article 3, Clause 2 (Excluded Activities) of Ministerial Decision No. 229 of 2025
Nexus Requirement
Mainland licensing or specific agricultural land-use permits
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX