Sovereign Verdict
EXCLUDED
Statutory ISIC
031
Regulatory Activity Scope
Fishing
"Under the UAE CT framework, the extraction of natural resources is an Excluded Activity. Fishing (ISIC 031) involves the harvesting of biological natural resources. Unless the entity is strictly performing 'Processing' (ISIC 1020) as a separate Qualifying Activity, the primary income from the catch is subject to the 9% headline rate as it fails the Qualifying Activity test under the 'Extraction' exclusion."
Forensic Audit Red Flag
Attempting to recharacterize 'Extraction of Natural Resources' as 'Manufacturing or Processing of Goods' to illicitly access the 0% regime
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 2; Cabinet Decision No. 55 of 2023, Article 3
Nexus Requirement
Requires MOCCAE commercial fishing license and vessel registration within a designated UAE port/Free Zone jurisdiction
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX