Sovereign Verdict
EXCLUDED
Statutory ISIC
03
Regulatory Activity Scope
Fishing and aquaculture
"Fishing and aquaculture are primary sector activities. Under the UAE Corporate Tax framework, specifically the list of Qualifying Activities for Free Zone Persons, primary extraction and harvesting are not included. Consequently, income from these activities is treated as taxable at the standard 9% rate once the threshold is exceeded, even if conducted by a Free Zone Person."
Forensic Audit Red Flag
Recharacterizing primary aquaculture harvesting as 'Manufacturing of Food Products' to illicitly claim Qualifying Activity status under the 0% regime
Statutory Authority
Ministerial Decision No. 265 of 2023, Article 3; MD 229 of 2025, Clause 4
Nexus Requirement
Physical presence in UAE with local municipal or environmental licensing; no specific Free Zone 0% benefit for primary production
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX