Union Budget 2025: Presumptive taxation for non-residents may give a boost to chip manufacturing

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chip manufacturing, spot   manufacturing fund  2025The determination could assistance India's aspirations of becoming a semiconductor manufacturing base. (Reuters/File)

In her fund code Saturday, Finance Minister Nirmala Sitharaman announced a caller presumptive taxation authorities for non-residents providing services successful India’s electronics manufacturing assemblage that experts said could importantly slash the taxation load connected their income successful India.

The determination could springiness a fillip to overseas technicians and entities moving successful the electronics assemblage successful India, and assistance the country’s aspirations of becoming a semiconductor manufacturing base. As companies determination to acceptable up manufacturing operations successful the country, including successful sectors similar chips, it would necessitate overseas companies and their technicians to enactment successful India for a prolonged play successful bid to instal and tally superior goods, similar machinery.

“…it has been represented that non-residents volition beryllium providing enactment successful mounting up of specified electronics manufacturing facilities by deploying the exertion and providing enactment services. In bid to guarantee certainty and promotion of this industry, it is projected to supply a presumptive taxation authorities for non-residents engaged successful the concern of providing services oregon exertion to a nonmigratory company, which is establishing oregon operating electronics manufacturing facility…” the memorandum to the Union Budget 2025-26 stated.

It is projected that a caller conception — 44BBD — successful the Income Tax Act, which deems 25 per cent of the aggregate magnitude received connected relationship of providing specified services volition effect successful an effectual taxation payable of little than 10 per cent connected gross receipts, by a non-resident company. This amendment volition instrumentality effect from the archetypal time of April, 2026, and shall accordingly, use successful narration to the appraisal twelvemonth 2026-27 and consequent appraisal years

Sandeep Sehgal, partner, tax, AKM Global, a taxation and consulting firm, said, “25 per cent of their gross from their manufacturing installation successful India shall beryllium considered arsenic income and shall beryllium taxed astatine 35 per cent. Hence, their effectual taxation complaint volition beryllium little than 10 per cent. This measurement whitethorn service arsenic a important boost for the industry, helping bring exertion and qualified enactment to India.”

Festive offer

The Finance Minister has besides projected an amendment to a proviso nether Section 9 of the Income Tax Act truthful that the transactions oregon activities of a non-resident successful India that are confined to the acquisition of goods successful India for the intent of export shall not represent important economical beingness of specified non-resident successful India.

Dwaraknath E N , Partner, Price Waterhouse & Co LLP, said: “…the connection to exclude activities that are confined to the acquisition of goods for purposes of export from the explanation of ‘significant economical presence’ is besides a measurement toward greater certainty for non-residents.”

Soumyarendra Barik is Special Correspondent with The Indian Express and reports connected the intersection of technology, argumentation and society. With implicit 5 years of newsroom experience, helium has reported connected issues of gig workers’ rights, privacy, India’s prevalent integer disagreement and a scope of different argumentation interventions that interaction large tech companies. He erstwhile besides tailed a nutrient transportation idiosyncratic for implicit 12 hours to quantify the magnitude of wealth they make, and the symptom they spell done portion doing so. In his escaped time, helium likes to nerd astir watches, Formula 1 and football. ... Read More

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