Short answer. Yes. Article 71 ends with a proviso that the person or enterprise wishing to avail of the incentive should pay his apprentices the minimum wage. The deduction and the wage are tied: an employer paying apprentices below the applicable minimum has not met the article's own condition for claiming it.
What the law says
the person or enterprise who wishes to avail himself or itself of this incentive should pay his apprentices the minimum wage
Labor Code, Article 71 — Deductibility Of Training Costs. Read the full provision →
The proviso, and where it sits
The condition is the last of three in a single sentence: the person or enterprise who wishes to avail himself or itself of this incentive should pay his apprentices the minimum wage. Its placement is the point. It is not a separate wage rule that happens to appear nearby; it is a term of the incentive, expressed as something the enterprise wishing to avail of the benefit must do. The provision is drafted so that the tax advantage and the apprentices' pay rise or fall together, which is a deliberate piece of design rather than an accident of arrangement.
What it does and does not decide
This is where employers get confused, so it is worth stating carefully. Article 71 is about entitlement to the deduction. Whatever position applies elsewhere in the Code to apprentice wage rates generally, this article makes payment of the minimum wage the price of the incentive specifically. So an employer may face a real question about how it must pay apprentices — but there is no question at all about the deduction: an enterprise paying its apprentices less than the minimum wage has simply not satisfied the condition the grant is expressed to depend on.
The condition travels with two others
The wage proviso is not severable from the rest of the sentence. The same article requires that the apprenticeship programme be duly recognised by the Department of Labor and Employment, and caps the deduction at ten percent of direct labor wage. A claim has to answer all three. Companies tend to prepare carefully for the arithmetic ceiling, which is visible in the accounts, and to overlook the other two, which are not — recognition is a document somebody has to have obtained, and the wage condition is a fact about payroll month by month.
Reconciling the claim with the payroll
The practical exercise is to lay the two records side by side before anything is filed. Take the apprenticeship agreements and the payroll for the period, identify the minimum wage applicable to your region and industry, and confirm that every apprentice covered by the claim was paid at or above it throughout. Where an apprentice was underpaid for even part of the period, that is a fact to raise with your adviser rather than to leave for an examiner to find. The article's conditions are checkable from your own documents, which is how they will be checked.