Growing of grapes

Excluded · 9% taxable

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

ISIC 0121 pertains to primary production. Under the framework established by Ministerial Decision No. 229 of 2025, primary agriculture is not categorized as a Qualifying Activity for Free Zone Persons. Consequently, income generated from the growing of grapes is treated as Excluded Income, subject to the standard 9% corporate tax rate regardless of the entity's location in a Free Zone.

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Legal Reference

Ministerial Decision No. 229 of 2025, Article 3, Clause 2(g)

Audit Red Flag

Artificial bundling of primary agricultural income with 'Processing of Food' to illicitly claim Qualifying Activity status under the 0% regime.

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