Activities under ISIC 949 are generally considered 'Excluded Activities' for Qualifying Free Zone Persons (QFZP) as they do not fall under the exhaustive list of Qualifying Activities. Unless the entity is specifically designated as a 'Public Benefit Entity' under Article 9 of the Corporate Tax Law via Cabinet Decision, income is subject to the standard 9% rate. Forensic focus is on the 'De Minimis' threshold if the entity attempts to maintain QFZP status while earning non-qualifying membership revenue.
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Legal Reference
Article 9 (Exempt Persons) and Ministerial Decision No. 229 of 2025 regarding Qualifying Income.
Audit Red Flag
Reclassification of commercial service fees or consultancy income as 'membership subscriptions' to exploit the 0% rate or exempt status.