Reproduction of recorded media

ISIC 182 is categorized under Manufacturing. Under Ministerial Decision No. 229 of 2025, the physical reproduction of media from master copies constitutes 'Manufacturing and processing of goods'. Forensic auditors must verify that the income is derived from the physical replication process rather than the underlying intellectual property royalties, which may be subject to different nexus or exclusion rules if not managed as a Qualifying Intellectual Property.

Audit Red Flag

Reclassification of intangible IP licensing fees or digital distribution revenue as physical 'manufacturing' income to exploit the 0% rate.

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