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CBDT Notifies Amendments to Income-Tax Rules, 1962 for Presumptive Taxation of Non-Resident Cruise Ship Operators

The Central Board of Direct Taxes (CBDT) has issued Notification No. 9/2025 dated 21st January 2025, prescribing conditions for the applicability of the presumptive taxation regime for non-resident entities engaged in the operation of cruise ships in India. This measure aligns with the provisions introduced under the Finance (No. 2) Act, 2024, aimed at promoting investment and employment in the tourism and shipping sectors.

Key Highlights of the Presumptive Taxation Regime

  1. Scope of Applicability:
    The regime applies to non-resident entities engaged in the business of operating cruise ships for leisure and recreation purposes in India.

  2. Exemption on Lease Rentals:
    Income from lease rentals of cruise ships received by a foreign company from a related company operating such ships in India is exempt from taxation.

  3. Conditions for Applicability:
    To qualify under the presumptive taxation regime, the non-resident entity must meet the following criteria:

    • Operate passenger ships with a carrying capacity of over 200 passengers or a length of 75 meters or more, equipped with appropriate dining and cabin facilities.
    • Operate ships on scheduled voyages or shore excursions touching at least two Indian sea ports or the same port twice.
    • Operate ships primarily for passenger transportation, not for cargo.
    • Adhere to procedures and guidelines issued by the Ministry of Tourism or Ministry of Shipping.

Objective of the Amendment

This initiative underscores the Government's commitment to fostering the growth of the cruise tourism sector, attracting foreign players, and boosting employment opportunities in India.

For further details, refer to CBDT Notification No. 9/2025 available on the e-Gazette portal.


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