Office administrative, office support and other business support activities
4 activity groups
Mixed · depends on counterparty
Forensic Analysis
DZ requiredSubstance: STANDARDAI-derived
Under Ministerial Decision No. 229 of 2025, ISIC 82 activities are generally non-qualifying when provided to third parties. They only achieve Qualifying Income status if they constitute 'Headquarter Services' or 'Administrative Services' provided specifically to Related Parties. Forensic audit will focus on the 'Related Party' nexus and the substance of management control.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 2, Clause 1(f) and Article 3
Audit Red Flag
Reclassifying third-party Business Process Outsourcing (BPO) or call center revenue as 'Headquarter Services' to Related Parties to illicitly access the 0% rate.