Manufacture of motor vehicles, trailers and semi-trailers

Manufacturing is a Qualifying Activity. Forensic focus is required on the 'De Minimis' threshold (5% or AED 5m) regarding ancillary services such as vehicle maintenance or repair, which are often bundled but may constitute non-qualifying income. Verification of physical assembly and quality control CIGA within the zone is mandatory to prevent PE (Permanent Establishment) triggers in the mainland.

Audit Red Flag

Inappropriate allocation of 'Embedded IP' royalties or B2C retail sales of vehicles being masked as B2B manufacturing revenue to circumvent Excluded Activity status.

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