Manufacturing of goods is a Qualifying Activity under the Free Zone regime. Forensic scrutiny focuses on the physical presence of plant, machinery, and specialized personnel. If the transport equipment is leased rather than sold, the income may be reclassified under 'Leasing of Aviation/Ship Assets' which has distinct regulatory requirements.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 2, Clause 1(a)
Audit Red Flag
Attributing income to the Free Zone entity when the actual fabrication or assembly (CIGA) is outsourced to a mainland subsidiary or third party.