Under the scope of 'Manufacturing and processing of goods or materials', ISIC 139 requires the transformation of raw materials (fibers/yarns) into new products. Forensic auditors will verify the 'substantial transformation' test. If the activity is deemed mere 'trading' without processing, and the counterparty is a non-DZ person, the income may be reclassified as non-qualifying.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 2, Clause 1(a)
Audit Red Flag
Classification of 'simple assembly' or 're-packaging' as 'manufacturing' to illicitly access the 0% regime without substantial transformation of the textile goods.