Manufacture of irradiation, electromedical and electrotherapeutic equipment

Qualifying · 0% eligible

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Activity falls under 'Manufacturing of goods or materials'. Forensic audit will focus on the 'Substantial Transformation' test to ensure the medical equipment is actually produced in the DZ rather than merely assembled or repackaged. Income derived from Intellectual Property (IP) embedded in the equipment must be arm's length to prevent profit shifting from non-qualifying IP regimes.

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Legal Reference

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

Audit Red Flag

Re-characterization of high-margin 'After-Sales Maintenance' or 'Software-as-a-Service' (SaaS) updates as 'Manufacturing Income' to evade the 5% de minimis threshold.

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