Under the 2025 framework, 7010 is scrutinized for CIGA (Core Income Generating Activities). Auditors will verify if the HQ actually incurs operating expenditures and employs full-time qualified personnel locally, rather than acting as a conduit for a foreign parent's decisions.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 2, Clause 1(c)
Audit Red Flag
Discrepancy between the 'Place of Effective Management' (POEM) and the physical location of C-suite executives during strategic decision-making cycles.
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