Manufacture of electronic components and boards

Qualifying · 0% eligible

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Under MD 229 of 2025, manufacturing is a Qualifying Activity. Forensic focus is on Core Income Generating Activities (CIGA), specifically the physical assembly and testing of components. If R&D or IP licensing is bundled into the manufacturing price without proper functional separation, the FTA may recharacterize the income as non-qualifying IP income.

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Legal Reference

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

Audit Red Flag

Misclassification of 'Toll Manufacturing' as 'Own Manufacturing' where the entity lacks control over raw materials and production risks.

2 licensable activities under this classification

Electronic Tubes ManufacturingExternal approval required

Electronic Wafers & Semiconductors ManufacturingExternal approval required

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