Under MD 229 of 2025, leasing of ships and aircraft remains Qualifying, but general rental of motor vehicles and personal goods (ISIC 7710-7729) is Excluded unless the counterparty is a Qualifying Free Zone Person (QFZP) who is the beneficial recipient. Forensic focus is on the 'use and enjoyment' location of the leased asset.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 2, Clause 1(i) and Article 3
Audit Red Flag
Embedded finance components in operating leases being recharacterized as 'Financial Services' (Excluded Activity) to trigger the 5% De Minimis breach.