Mining of hard coal

Excluded · 9% taxable

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Mining of hard coal is classified as an Extractive Activity. Under Article 7 of the Corporate Tax Law, income from extractive activities is subject to Emirate-level taxation and is excluded from the Qualifying Free Zone Person regime to preserve sovereign resource rights. Ministerial Decision No. 229 of 2025 reinforces that any income derived from the exploitation of natural resources remains outside the scope of the 0% federal rate.

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Legal Reference

Article 7 and Article 8 of Federal Decree-Law No. 47 of 2022; Ministerial Decision No. 229 of 2025, Article 3, Clause 1

Audit Red Flag

Reclassification of extraction revenue as 'wholesale distribution' or 'commodity trading' to bypass the extractive activity exclusion.

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