Other human resources provision

Under Ministerial Decision No. 229 of 2025, HR provision is treated as a service. If the recipient is a Mainland person, the income is Excluded (9%). If the recipient is a Free Zone person, it is Qualifying (0%) only if it is not an 'Excluded Activity'. Forensic auditors will verify if the personnel provided are performing 'Excluded Activities' (e.g., banking or insurance) which would taint the income stream.

Audit Red Flag

Reclassifying 'Manpower Supply' (ISIC 783) as 'Headquarter Services' or 'Management Services' to Related Parties to exploit the 0% rate without meeting the specific CIGA requirements for HQ functions.

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