Mining support services (ISIC 09) are directly ancillary to Extractive Business. Under the UAE CT framework, Extractive Businesses are subject to Emirate-level taxation and are specifically listed as 'Excluded Activities' for Qualifying Free Zone Persons to prevent the erosion of local sovereign tax bases. Income derived from these activities is taxed at the standard 9% rate if not subject to Emirate-level tax, or is entirely outside the scope of CT if the Article 7 exemption applies.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 3, Clause 1(g) in conjunction with Federal Decree-Law No. 47 of 2022, Article 7
Audit Red Flag
Re-characterizing drilling or site preparation fees as 'Technical Consulting' or 'Equipment Rental' to attempt to qualify for the 0% regime under 'Qualifying Services'.