Sovereign Verdict
EXCLUDED
Statutory ISIC
0312
Regulatory Activity Scope
Freshwater fishing
"Under Ministerial Decision No. 229 of 2025, primary production and extraction of natural resources are categorized as Excluded Activities. While 'Processing of Food' may be a Qualifying Activity, the actual act of freshwater fishing (ISIC 0312) remains subject to the standard 9% rate if the de minimis threshold is exceeded, as it does not constitute a Qualifying Activity for Free Zone Persons."
Forensic Audit Red Flag
Attempting to bundle 'extraction' (fishing) with 'processing' (manufacturing) to claim 0% on the entire value chain.
Statutory Authority
Article 3, Clause 1(g) of Ministerial Decision No. 229 of 2025
Nexus Requirement
Local environmental permit and MOCCAE commercial fishing license required
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX