Manufacture of coke and refined petroleum products

While ISIC 19 covers downstream processing, any integration with upstream extraction (ISIC 05-09) triggers exclusion. Auditors will scrutinize the 'Qualifying Income' vs 'Excluded Income' split, specifically looking for transfer pricing manipulation on raw crude feedstock sourced from related parties.

Audit Red Flag

Commingling of income from 'Extractive' activities (Excluded) with 'Manufacturing' activities (Qualifying) without distinct cost-center accounting.

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