Growing of pome fruits and stone fruits

Excluded · 9% taxable

Forensic Analysis

DZ requiredSubstance: STANDARDAI-derived

Primary production (ISIC 0124) is not defined as a Qualifying Activity. Income from the sale of pome and stone fruits is categorized as Non-Qualifying Income. Under the QFZP regime, if this income exceeds the de minimis threshold (the lower of 5% of total revenue or AED 5,000,000), the entity loses its Qualifying status for the relevant tax period. Forensic focus is on the distinction between raw harvest sales and value-added manufacturing.

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Legal Reference

Ministerial Decision No. 229 of 2025, Article 2; Cabinet Decision No. 100 of 2023, Article 3

Audit Red Flag

Attempting to reclassify primary agricultural 'growing' as 'manufacturing' or 'processing' to qualify for the 0% rate under MD 265 of 2023.

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