Manufacture of non-metallic mineral products n.e.c.

ISIC 239 involves the production of glass, ceramics, and cement. Under MD 229 of 2025, 'Manufacturing of goods or materials' is a Qualifying Activity. Forensic auditors will verify the 'Substantial Transformation' test to ensure the activity is not merely 'Distribution' (which has different nexus rules). Adequate Core Income Generating Activities (CIGA) must be performed within the Designated Zone, including CAPEX for machinery and specialized labor.

Audit Red Flag

Misclassification of 'Trading' as 'Manufacturing' where no substantial transformation of raw materials occurs on-site.

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