Repair of fabricated metal products, machinery and equipment

ISIC 331 is categorized under 'Manufacturing and Processing' for CT purposes. Forensic focus is on whether the repair constitutes a 'substantial transformation' or 'restoration of utility' that qualifies as processing. Income from Mainland customers is subject to the 5% de minimis rule unless the activity is performed within a Designated Zone for a customer who is the ultimate importer of the repaired goods.

Audit Red Flag

Re-characterization of 'Repair' as 'Manufacturing' to claim 0% rate on income from Mainland persons without meeting the 'Processing of Goods' threshold.

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