Manufacture of computers and peripheral equipment

Under MD 229 of 2025, 'Manufacturing of goods or materials' is a Qualifying Activity. Forensic auditors will apply the 'Substantial Transformation' test to ensure the process is not merely 'minor assembly' or 'packaging' which would reclassify the revenue as Excluded Income (Trading). Verification of Core Income-Generating Activities (CIGA) requires proof of physical machinery depreciation and specialized technical labor on the Free Zone payroll.

Audit Red Flag

Artificial fragmentation of the value chain where high-value R&D/IP is held in a mainland branch while low-value assembly is claimed as Qualifying Manufacturing income.

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