Wholesale on a fee or contract basis

ISIC 461 covers activities on a fee or contract basis (agents/brokers). Unlike principal wholesaling, this is categorized as a service. Under MD 229 of 2025, if the service is provided to a Mainland person, it is Excluded Income. If provided to a Free Zone Person or a Foreign Person, it may be Qualifying Income, provided it is not a 'Mandatory Excluded Activity' such as certain regulated financial services.

Audit Red Flag

Misclassification of brokerage commission as 'Distribution of Goods' to claim 0% tax without taking legal title or physical possession of inventory.

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