Residential care activities for mental retardation, mental health and substance abuse

Residential care for mental health requires significant Core Income-Generating Activities (CIGA) including 24/7 clinical supervision and specialized therapeutic intervention. Under Ministerial Decision No. 229 of 2025, healthcare is a Qualifying Activity; however, forensic scrutiny will focus on the separation of medical treatment from general social work or non-clinical residential services which may fall under Excluded Activities.

Audit Red Flag

Mischaracterization of non-medical 'hospitality' or 'room and board' revenue as 'Qualifying Healthcare Services' to inflate 0% tax base.

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