Wholesale of food and tobacco falls under 'Distribution of goods or materials' in a Designated Zone. Forensic auditors will reconcile Excise Tax filings for tobacco and carbonated beverages against Corporate Tax returns to verify volume and counterparty status (Natural vs. Juridical persons).
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 2, Clause 1(l)
Audit Red Flag
Commingling of B2B wholesale revenue with B2C retail sales to natural persons, which disqualifies the entire income stream from the 0% regime.
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