ISIC 9000 is not explicitly listed as a 'Qualifying Activity' under the primary schedule. Therefore, income is only qualifying if it constitutes 'Income from transactions with a Free Zone Person' where that person is the Beneficial Recipient. Forensic focus is on the 'Mainland-sourced' vs 'Free Zone-sourced' revenue split and the verification of the 'Beneficial Recipient' status of clients.
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Legal Reference
Ministerial Decision No. 229 of 2025, Article 3, Clause 1(a) and Article 4
Audit Red Flag
Revenue leakage from B2C transactions (e.g., ticket sales to individuals or private commissions) exceeding the 5% or AED 5,000,000 de minimis threshold, reclassifying all income as taxable at 9%.
16 licensable activities under this classification
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