Manufacturing is a Qualifying Activity under the Free Zone regime. Forensic auditors will verify the 'substantial transformation' threshold to ensure the activity is not a masked 'Excluded Activity' (e.g., distribution to mainland). If the entity operates in a non-Designated Zone, income from the sale of these food products to mainland persons will be taxed at 9% unless the 'De Minimis' rule applies.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 2, Clause 1(a)
Audit Red Flag
Misclassification of 'Trading' or 'Distribution' as 'Manufacturing' where only minor assembly or repackaging occurs without substantial transformation of raw materials.