Secondary education

Education is classified as a Qualifying Activity. While generally B2C services are excluded, Education is a specific carve-out allowing transactions with natural persons. Forensic focus is on the 'Core Income Generating Activities' (CIGA) which require physical presence of teaching staff and curriculum development within the zone.

Audit Red Flag

Commingling of 'Qualifying' tuition fees with 'Excluded' commercial revenue such as retail sales of uniforms, books, or third-party canteen commissions exceeding the 5% de minimis threshold.

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