Agriculture, forestry and fishing

Under the framework of Ministerial Decision No. 229 of 2025, primary production activities under ISIC Code A are not categorized as Qualifying Activities. Revenue generated from the extraction of natural resources or primary biological transformation is treated as Non-Qualifying Revenue, subjecting the entity to the 9% corporate tax rate regardless of Free Zone status, unless the activity is ancillary to a permitted manufacturing process.

Audit Red Flag

Recharacterization of primary agricultural production as 'Manufacturing or Processing of Goods' to illicitly access the 0% Qualifying Income rate.

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