Sovereign Verdict
EXCLUDED
Statutory ISIC
0311
Regulatory Activity Scope
Marine fishing
"Marine fishing is categorized as an extractive activity involving the exploitation of natural resources. Under the UAE Corporate Tax framework, income from extractive activities is generally excluded from the 0% Free Zone regime to preserve Emirate-level sovereign rights over natural resources. If conducted by a Free Zone Person, it is treated as an Excluded Activity, potentially disqualifying the entity from the 0% rate on other income via the de minimis rule violation."
Forensic Audit Red Flag
Attempting to reclassify 'extraction of natural resources' as 'manufacturing' or 'logistics' to claim Qualifying Income status
Statutory Authority
Article 7 of Federal Decree-Law No. 47 of 2022 and Ministerial Decision No. 229 of 2025, Clause 3(1)(a)
Nexus Requirement
Requires MOCCAE federal fishing permit and local Emirate-level environmental licensing
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX