Section 44BBD is proposed presumptive taxation scheme for non-resident companies those who will be providing services or technology in India. To ensure tax certainty and promote Electronics Manufacturing industry, a new presumptive taxation scheme is proposed under Section 44BBD for non-residents.
| As per Budget 2025 In order to ensure certainty and promotion of this industry, it is proposed to provide a presumptive taxation regime for non-residents engaged in the business of providing services or technology, to a resident company which are establishing or operating electronics manufacturing facility or a connected facility for manufacturing or producing electronic goods, article or thing in India, under a scheme notified by the Central Government in the Ministry of Electronics and Information Technology and satisfies such conditions as prescribed in the rules. |
Effective Date
- The amendment will apply from April 1, 2026.
- It will be effective for AY 2026-27 onwards.
Objective
To make India a global hub for Electronics System Design and Manufacturing, a comprehensive program for the development of semiconductors and display manufacturing ecosystem.
Role of Non-Residents
Non-resident companies will be given support in setting up electronics manufacturing facilities in India by:
- Providing technology
- Offering support services
Who will be benefited?
Non-residents providing services or technology to a resident company engaged in electronics manufacturing under a notified government scheme.
Deemed Profit Calculation
25% of the total revenue received by the non-resident will be considered as taxable profit.
Effective Tax Rate
The effective tax payable will be less than 10% on gross receipts for non-resident companies.