Under MD 229 of 2025, technical testing is qualifying only if performed within a Designated Zone for goods/materials or if provided as a 'Service to Related Parties'. Standalone testing for third-party mainland clients or international clients without a DZ nexus is treated as Excluded Income. Forensic audit will focus on the physical location of the testing equipment and the relationship of the counterparty.
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Legal Reference
Article 2(1)(c) and Article 3(1)(j) of Ministerial Decision No. 229 of 2025
Audit Red Flag
Misclassifying standalone third-party testing services as 'Processing of Goods' or 'Ancillary to Manufacturing' to evade the 9% rate on non-qualifying service income.
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