Publishing activities

Publishing activities (ISIC 58) primarily generate income from the exploitation of Intellectual Property. Under Ministerial Decision No. 229 of 2025, income from IP is generally excluded from the 0% rate unless it meets the definition of 'Qualifying Intellectual Property' and follows the OECD-compliant nexus approach. Since publishing is not listed as a 'Qualifying Activity' under Article 2, it is treated as 'Excluded Income' unless it falls within the de minimis threshold.

Audit Red Flag

Recharacterizing royalty income from copyrighted publications as 'consultancy' or 'service fees' to avoid the IP Nexus compliance burden.

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