**Executive Summary**
The document summarizes key proposals from the Union Budget 2026-27, presented to Parliament on February 1, 2026. It outlines tax exemptions and safe harbors aimed at boosting investment in data centers, encouraging toll manufacturing, and attracting global talent to India. A key provision is the tax holiday till 2047 for foreign companies providing cloud services from India.
**Key Points / Main Content**
* **Cloud Services & Data Centers:**
* Tax holiday till 2047 for foreign companies providing cloud services globally using Indian data centers, provided services are offered to Indian customers through a local reseller entity.
* Safe harbor of 15% on cost for companies providing data center services from India, if the company is a related entity.
* **Component Warehousing:**
* Safe harbor provision for non-residents involved in component warehousing in a bonded warehouse, with a profit margin of 2% of the invoice value (approximately 0.7% tax).
* **Toll Manufacturing:**
* Income tax exemption for 5 years to non-residents providing capital goods, equipment, or tooling to toll manufacturers in a bonded zone.
* **Global Talent:**
* Exemption on global (non-India sourced) income for non-resident experts for a period of 5 years under notified schemes.
* **Minimum Alternate Tax (MAT):**
* Exemption from Minimum Alternate Tax (MAT) for all non-residents who pay tax on a presumptive basis.
**Impact Analysis**
**Foreign Companies Providing Cloud Services**
* **Impact**: Benefits from long term tax holiday to enhance revenue and reduce operating expenses.
* **Action Required**: Structure operations to ensure compliance with the requirement of providing services to Indian customers through a local reseller entity.
**Non-Residents Engaged in Component Warehousing**
* **Impact**: Reduced tax burden on warehousing operations.
* **Action Required**: Leverage the new safe harbor provision for tax planning and efficient logistics.
**Non-Residents Providing Capital Goods to Toll Manufacturers**
* **Impact**: Tax exemption enhances profitability and competitiveness in the toll manufacturing sector.
* **Action Required**: Partner with toll manufacturers in India to leverage the tax benefits.
**Non-Resident Experts**
* **Impact**: Encourages global talent to work in India by providing tax exemptions on global income.
* **Action Required**: Consider relocation or extended stays in India to take advantage of the tax benefits.
**Non-Residents Paying Tax on Presumptive Basis**
* **Impact**: Reduced tax burden by waiving MAT.
* **Action Required**: Review tax strategies to account for the MAT exemption.
Key Entities Referenced
Union Budget 2026-27: A key policy document proposing tax exemptions and a 'safe harbor' for foreign companies providing cloud services and related activities in India.
Minimum Alternate Tax (MAT): Tax from which non-residents paying tax on a presumptive basis are proposed to be exempted.
Ministry of Finance: The government ministry responsible for presenting the Union Budget and related tax proposals.
Ministry of Finance
EXEMPTION FROM MINIMUM ALTERNATE TAX
(MAT) TO ALL NON-RESIDENTS WHO PAY TAX
ON PRESUMPTIVE BASIS
TAX HOLIDAY TILL 2047 TO ANY FOREIGN COMPANY THAT
PROVIDES CLOUD SERVICES TO CUSTOMERS GLOBALLY
BY USING DATA CENTRE SERVICES FROM INDIA
SAFE HARBOUR OF 15 PERCENT ON COST IN CASE THE
COMPANY PROVIDING DATA CENTRE SERVICES FROM
INDIA IS A RELATED ENTITY
प्रव तथ: 01 FEB 2026 12:51PM by PIB Delhi
Recognising the need to enable critical infrastructure and boost investment in data centres,the Union
Minister for Finance and Corporate Affairs, Smt. Nirmala Sitharaman,while presenting the Union Budget
2026-27 in Parliament today, proposed to provide tax holiday till 2047 to any foreign company that
provides cloud services to customers globally by using data centre services from India. It will, however,
need to provide services to Indian customers through an Indian reseller entity.
The Union Budget also proposes to provide a safe harbour of 15 percent on cost in case the company
providing data centre services from India is a related entity.
To harness the efficiency of just-in-time logistics for electronic manufacturing, the Union Finance
Ministerproposed in the budget to provide safe harbour to non-residents for component warehousing in a
bonded warehouse at a profit margin of 2 percent of the invoice value. The resultant tax of about 0.7
percent will be much lower than in competing jurisdictions.
The Union Finance Minister in order to provide fillip to toll manufacturing in India, hasproposedin the
Union budget 2026-27, to provide exemption from income tax for 5 years, to any non-resident
whoprovides capital goods, equipment or tooling, to any toll manufacturer in a bonded zone.
The Budget proposals also provide exemption to global (non-India sourced) income of a non-resident
expert, for a stay period of 5 years under notified schemes. This is intended to encourage vast pool of
global talent to work in India for a longer period of time
The Union budget also proposes to provide exemption from Minimum Alternate Tax (MAT) to all non-
residents who pay tax on presumptive basis.
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