ISIC 829 is a residual category. Under MD 229 of 2025, business support only qualifies if it meets the definition of 'Headquarter Services' or 'Administrative Services' to Related Parties. General support services provided to third parties are treated as Non-Qualifying Income, subject to the 5% de minimis rule or the 9% headline rate.
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Legal Reference
Article 2(1)(j) and Article 3 of Ministerial Decision No. 229 of 2025
Audit Red Flag
Revenue from third-party clients being erroneously categorized as 'Qualifying' under the guise of 'Headquarter Services' which are strictly intra-group.