Electricity, gas, steam and air conditioning supply

3 activity groups

Excluded · 9% taxable

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Under the Qualifying Income framework, the distribution of natural gas and electricity is explicitly listed as an Excluded Activity. ISIC 35 covers the generation and distribution of power and cooling; income derived from these activities by a Qualifying Free Zone Person is subject to the 9% Corporate Tax rate as it fails the 'Qualifying Income' test, regardless of the customer's location.

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Legal Reference

Article 3(1)(f) of Ministerial Decision No. 139 of 2023 (as refined by MD 229 of 2025)

Audit Red Flag

Re-characterization of utility supply as 'property management services' or 'ancillary facility fees' to circumvent the Excluded Activity classification.

Browse activity groups

ISIC 351

Excluded · 9% taxable

Electric power generation, transmission and distribution

2 licensable activities

DZ required

ISIC 352

Excluded · 9% taxable

Manufacture of gas; distribution of gaseous fuels through mains

1 licensable activity

DZ required

ISIC 353

Excluded · 9% taxable

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