Monday, 27 January 2025

CBDT notifies conditions for presumptive taxation of foreign cruise ship operators in India

 This Tax Alert explains the Notification  dated 21 January 2025 issued by the Central Board of Direct Taxes (CBDT) prescribing conditions for taxation of non-resident cruise ship operators in India under a new presumptive tax regime (new tax regime) applicable from tax year 2024-25 onwards.


The Finance (No. 2) Act, 2024 (FA 2024) introduced the new tax regime, for non-residents engaged in the business of operating cruise ships. The new tax regime, subject to conditions to be prescribed by rules, deems 20% of the specified amounts as income of the non-resident which is taxable at the corporate tax rate of 35% applicable for foreign companies.

Further, FA 2024 also introduced tax exemption for foreign company earning income from lease rentals of cruise ships paid by specified company subject to conditions prescribed thereunder. The specified company is a foreign company which (i) operates cruise ships in India, (ii) opts for the new tax regime and (iii) is also a subsidiary of the same holding company as the foreign company earning lease rentals.

The Notification provides conditions laying down technical specifications, route specifications, passenger carriage and compliance with regulatory guidelines for cruise ship operators under the new tax regime.

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CBDT notifies conditions for presumptive taxation of foreign cruise ship operators in India

  This Tax Alert explains the Notification   dated 21 January 2025 issued by the Central Board of Direct Taxes (CBDT) prescribing conditions...