Sovereign Verdict
EXCLUDED
Statutory ISIC
4711
Regulatory Activity Scope
Retail sale in non-specialized stores with food, beverages or tobacco predominating
"ISIC 4711 pertains to retail sales primarily to natural persons. Under the Free Zone Corporate Tax regime, 'Retail' is explicitly defined as an Excluded Activity. Income from this code will disqualify the Free Zone Person from the 0% regime if it exceeds the de minimis threshold (the lower of 5% of total revenue or AED 5,000,000). Forensic focus is on the 'Natural Person' test and the 'Designated Zone' physical delivery requirement."
Forensic Audit Red Flag
Artificial fragmentation of B2C retail transactions into B2B wholesale invoices to circumvent the 'Excluded Activity' classification.
Statutory Authority
Ministerial Decision No. 229 of 2025, Article 3, Clause 1(a)
Nexus Requirement
Physical presence within a Designated Zone required for de minimis calculation
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX