Software publishing

Qualifying · 0% eligible

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Software publishing is categorized under the 'Ownership, management and operation of Intellectual Property' framework. Under Ministerial Decision No. 229 of 2025, income from copyrighted software is Qualifying Income only if it meets the Nexus Approach. Forensic auditors will verify the 'Qualifying Expenditure' vs 'Overall Expenditure' to ensure the 0% rate is only applied to the proportion of income derived from local R&D activities.

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Legal Reference

Article 3, Clause 1(i) and Article 4 of Ministerial Decision No. 229 of 2025

Audit Red Flag

Misclassifying 'Custom Software Development' service fees as 'Software Publishing' royalty income to bypass the 5% de minimis rule on non-qualifying services.

1 licensable activity under this classification

Gaming PublisherExternal approval required

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