Special taxation regime applicable to non-residents and foreign companies : Clause 212 of Income Tax Bill, 2025 Vs. Section 115C of Income-tax Act, 1961

Foreign exchange asset definition narrows concessional tax eligibility for non-residents, affecting documentation and asset scope.

Clause 212 defines key terms for the concessional tax regime applicable to non-residents and foreign companies: foreign exchange asset (assets acquired with convertible foreign exchange), investment income (income from such assets), long-term capital gains (capital gains on foreign exchange assets not short-term), non-resident Indian (citizen or person of Indian origin who is not resident) and specified asset (shares, certain debentures and deposits, government securities, and notified assets). The clause updates cross-references to current company law and retains notification powers, while omitting an explicit explanation of person of Indian origin and an in-text definition of convertible foreign exchange, creating potential interpretive need for rules or guidance.