Electric power generation, transmission and distribution

Under Ministerial Decision No. 229 of 2025, the provision of regulated utilities is explicitly categorized as an Excluded Activity. While generation for captive use within a Free Zone may be incidental to a Qualifying Activity (like Manufacturing), the commercial transmission and distribution of electricity are treated as non-qualifying to prevent erosion of the mainland tax base.

Audit Red Flag

Misclassification of 'Mainland Source Income' as 'Qualifying Income' when power is exported to the national grid or mainland consumers.

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