Combined facilities support activities

ISIC 811 involves multi-disciplinary support. Under MD 229 of 2025, income is Qualifying only if the counterparty is a Free Zone Person and the services do not relate to Immovable Property located in the Mainland. Forensic focus is on the 'Immovable Property' carve-out; if services are tied to a specific Mainland asset, the income is taxed at 9% regardless of the provider's QFZP status.

Audit Red Flag

Bundling of maintenance services for Mainland-based immovable property into a Free Zone 'management' contract to exploit the 0% rate.

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