ISIC 4220 involves the development of immovable property. Under the UAE CT framework, income from immovable property (specifically construction and development) is generally excluded from the 0% Qualifying Income regime for Free Zone Persons when the property is located outside the Free Zone or involves non-Free Zone persons. Forensic focus is on the 'Site Office' constituting a Fixed Place of Business PE.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 5 (Exclusions related to Immovable Property)
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Reclassification of 'Construction Services' as 'Technical Consulting' or 'Project Management' to bypass the immovable property exclusion list.
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