Growing of citrus fruits

Excluded · 9% taxable

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

ISIC 0123 pertains to primary production. Under the framework established by Ministerial Decision No. 229 of 2025, primary agricultural activities do not constitute 'Manufacturing or Processing of goods'. Therefore, income derived from the sale of raw citrus fruits is treated as taxable at the standard 9% rate, even if conducted by a Qualifying Free Zone Person, unless it meets the de minimis requirements.

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Legal Reference

Article 3, Clause 1(g) of Ministerial Decision No. 229 of 2025

Audit Red Flag

Artificial fragmentation of income where 'Growing' (Excluded) is bundled with 'Processing' (Qualifying) to mask non-eligible primary production revenue.

2 licensable activities under this classification

Advanced Growing of Citrus FruitsExternal approval required

Growing of Fruit & Palm TreesExternal approval required

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