Manufacture of malt liquors and malt

Mixed · depends on counterparty

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Manufacturing is a Qualifying Activity under Article 2(1)(a). However, ISIC 1103 involves goods subject to Excise Tax. Forensic audit must verify that revenue is derived strictly from B2B wholesaling. Any direct-to-consumer distribution constitutes an Excluded Activity under Article 3, potentially tainting the QFZP status if the De Minimis limit is breached.

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Legal Reference

Ministerial Decision No. 229 of 2025, Article 2, Clause 1(a) and Article 3

Audit Red Flag

Misclassification of B2C 'tasting room' or retail sales as B2B manufacturing income to circumvent the 5% De Minimis threshold.

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