Under Ministerial Decision No. 229 of 2025, employment activities are categorized as Excluded Activities to prevent labor cost arbitrage. Forensic auditing focuses on the 'Economic Substance' of where the work is actually performed; if the staff provided by the Free Zone entity operate in the mainland, the income is disqualified from the 0% regime regardless of the entity's location.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 3, Clause 2(f)
Audit Red Flag
Recharging of staff costs to mainland affiliates where the personnel are physically performing duties in the mainland, triggering 'Deemed Mainland Source Income'.