ISIC 8299 is a residual category. Forensic scrutiny focuses on the 'n.e.c.' (not elsewhere classified) nature of the revenue. If the underlying activity constitutes an 'Excluded Activity' (e.g., certain financial services or brokerage) or is provided to Mainland third parties, it fails the Qualifying Income test unless it falls within the 5% de minimis threshold.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 2 (Qualifying Income) and Article 3 (Excluded Activities)
Audit Red Flag
Recharacterizing non-qualifying third-party administrative fees as 'Headquarter Services' or 'Treasury Services' to illicitly claim 0% tax.
13 licensable activities under this classification
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