Sovereign Verdict
MIXED
Statutory ISIC
0240
Regulatory Activity Scope
Support services to forestry
"ISIC 0240 is not categorized as a 'Qualifying Activity' per se under the primary list. Revenue is only qualifying if the recipient is a Qualifying Free Zone Person (QFZP) or if the income falls under the de minimis limit. If services are provided to Mainland UAE or involve immovable property (forest land) located in the Mainland, the income is taxed at 9%."
Forensic Audit Red Flag
Recharacterization of mainland-sourced service fees as 'offshore consulting' to bypass the 5% de minimis threshold for non-qualifying revenue.
Statutory Authority
Article 3, Clause 1(k) and Article 4 of Ministerial Decision No. 229 of 2025
Nexus Requirement
Must be licensed within a Free Zone/Designated Zone with specific activity permits for environmental or agricultural technical support.
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX