Other accommodation

Excluded · 9% taxable

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

ISIC 5590 covers student residences and worker hostels. Under MD 229 of 2025, income from Immovable Property is only Qualifying if derived from a Free Zone Person. Since 5590 typically involves transactions with natural persons (Non-Free Zone Persons), the income fails the Qualifying Income test and is subject to the 9% rate unless it falls within the De Minimis threshold.

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Legal Reference

Article 3, Clause 2(a) in conjunction with Article 5 of Ministerial Decision No. 229 of 2025

Audit Red Flag

Artificial characterization of rental income as 'service-based management fees' to circumvent the exclusion of income from Immovable Property derived from Non-Free Zone Persons.

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