Sovereign Verdict
EXCLUDED
Statutory ISIC
6411
Regulatory Activity Scope
Central banking
"Central banking (ISIC 6411) is inherently a sovereign function. Under Article 4(1)(a), Government Entities are Exempt Persons. Forensic scrutiny focuses on Article 5(6) compliance, ensuring that any non-mandated commercial activity is treated as a separate Taxable Business with independent financial statements."
Forensic Audit Red Flag
Failure to segregate sovereign functions from commercial activities conducted by subsidiaries that do not independently meet the criteria for Government Controlled Entities.
Statutory Authority
Article 4(1)(a) and Article 5 of Federal Decree-Law No. 47 of 2022
Nexus Requirement
Federal sovereign mandate and licensing under Decretal Federal Law No. 14 of 2018
2026 Substance Compliance
- Core Income Generating Activities (CIGA)
- Local Full-Time Employment Test
- Adequate Local OPEX