Other human resources provision

Mixed · depends on counterparty

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Under MD 229 of 2025, ISIC 7830 is only Qualifying if the personnel provision is performed for a Related Party. If the HR provision is for third-party clients, it constitutes Non-Qualifying Income. Forensic focus is on the 'Related Party' definition under Article 35 of the Corporate Tax Law and the actual direction and control of the provisioned staff.

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Legal Reference

Article 3(1)(g) of Ministerial Decision No. 229 of 2025

Audit Red Flag

Reclassification of third-party labor supply (Non-Qualifying) as 'Management Services' to Related Parties (Qualifying) to exploit the 0% regime.

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