Manufacture of agricultural and forestry machinery

Qualifying · 0% eligible

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Manufacturing of machinery is a Qualifying Activity under MD 229 of 2025. Forensic audit focus is on the physical presence of specialized equipment and technical staff. If the entity lacks the industrial capacity to actually 'manufacture' (ISIC 2821), the income may be reclassified as 'Trading', which is subject to the 9% rate if the counterparty is a Mainland person.

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Legal Reference

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

Audit Red Flag

Re-characterization of 'Simple Assembly' as 'Manufacturing'—the FTA will scrutinize the 'Substantial Transformation' test to ensure the process isn't merely packaging or minor assembly of imported kits.

2 licensable activities under this classification

Agricultural Tractors ManufacturingExternal approval required

Auto Irrigation Devices ManufacturingExternal approval required

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