Computer programming, consultancy and related activities

Under the 2025 framework, 'Ownership, management and operation of software' is a Qualifying Activity, but 'Consultancy' remains an Excluded Activity unless provided to other Free Zone Persons or qualifying as Headquarter Services. Forensic auditors will scrutinize the 'Nexus Approach' for R&D expenditure to ensure the 0% rate is only applied to income derived from qualifying IP developed by the entity.

Audit Red Flag

Bifurcation failure where high-margin professional consultancy fees (Excluded) are bundled into software maintenance or licensing contracts (Qualifying) to circumvent the 9% rate.

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