Presumptive taxation for cruise ship operations treats a portion of passenger receipts as deemed business profit subject to tax. Presumptive taxation applies to non-resident cruise ship operators meeting specified vessel, voyage and use criteria; a fixed percentage of aggregate passenger receipts is treated as deemed profit chargeable under Profits and Gains of Business or Profession without allowance for ordinary business deductions. A limited exemption excludes certain lease rental income of foreign lessors from total income where the lessor and the operator are subsidiaries of the same holding company, subject to the prescribed subsidiary-holding relationship.