Courier activities (ISIC 5320) fall under 'Logistics Services' as per the expanded definitions in MD 229 of 2025. Forensic scrutiny focuses on the 'Last-Mile' delivery component; if the delivery is performed by the Free Zone entity on the UAE Mainland, the income must be bifurcated to ensure it does not inadvertently create a Mainland Permanent Establishment or violate the 5% de minimis threshold for non-qualifying revenue.
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Legal Reference
Article 2, Clause 1(h) of Ministerial Decision No. 229 of 2025
Audit Red Flag
Reclassification of B2C (Business-to-Consumer) delivery revenue as Qualifying Income when it should be treated as Excluded Income under the de minimis rule.
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