Renting and leasing of motor vehicles

Under Ministerial Decision No. 229 of 2025, ISIC 771 is classified as an Excluded Activity. Unlike the leasing of aircraft or ships, motor vehicle leasing is specifically omitted from the Qualifying Activities list. Income derived from this activity is subject to the 9% Corporate Tax rate, and any attempt to bundle this with Qualifying Activities will be scrutinized under the de minimis rule (Article 4).

Audit Red Flag

Recharacterization of vehicle leasing as 'Logistics Services' or 'Equipment Rental' to circumvent the Excluded Activity list and claim the 0% rate.

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