Manufacturing of goods is a Qualifying Activity. However, ISIC 281 often involves complex machinery requiring onsite assembly. Forensic auditors will verify if the 'Core Income Generating Activity' (CIGA) for the manufacturing process is strictly contained within the DZ, and whether any ancillary services performed on the mainland are correctly carved out at the 9% rate.
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Legal Reference
Article 2, Clause 1(a) of Ministerial Decision No. 229 of 2025
Audit Red Flag
Inclusion of 'Installation and Commissioning' revenue earned on UAE Mainland within the 0% tax base, which constitutes a separate non-qualifying service.