Under ISIC 5210, the distinction between 'Logistics Services' and 'Income from Immovable Property' is critical. Forensic audit will verify if the taxpayer provides integrated cargo handling and inventory management (Qualifying) versus mere provision of floor space (potentially Excluded if the counterparty is not a QFZP). Substance must be evidenced by physical warehouse control and specialized staff.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 3, Clause 1(f)
Audit Red Flag
Re-characterization of storage service fees as passive rental income from immovable property to non-Free Zone persons.
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