Growing of other perennial crops

Excluded · 9% taxable

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Under Ministerial Decision No. 229 of 2025, primary production and extraction of natural resources or agricultural cultivation are not listed as Qualifying Activities. While the activity requires significant physical substance (land, irrigation, labor), it fails the 'Qualifying Activity' test for the 0% rate. Income derived from this ISIC code is treated as taxable at 9% unless it is incidental to a larger manufacturing process, which is strictly scrutinized.

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Legal Reference

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

Audit Red Flag

Attempting to reclassify 'Growing' (Excluded) as 'Processing of Agricultural Products' (Qualifying) without distinct industrial manufacturing facilities and separate cost centers.

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