This tracker records the legal timeline of the Gelephu Mindfulness City Special Administrative Region (GMC) using only verified commencement dates from the instruments themselves and gmc.bt/legislation, and keeps a watch list of provisions enacted but not yet in force. Basnet Law maintains it alongside the GMC Law Library.
What this guide covers
Timeline of GMC law
| Date | Event | Source |
|---|
| 10 February 2024 | Royal Charter No. 1 of 2024 granted by the Druk Gyalpo. GMC established as "a fully independent and autonomous region in the Kingdom of Bhutan" with executive, legislative and judicial authority (Art. 1). GMC Authority created (Art. 3) with power to make laws subject to Royal Assent (Art. 4). | Charter, Arts. 1, 3, 4 |
| 2024 | Application of Laws Act 2024 (Law No. 1 of 2024) enacted: the received common law and equity applied (s. 3); Schedule A applied statutes (s. 4); Schedule B applied financial services rules (s. 5); GMC Authority administers and enforces until separate bodies exist (s. 11). | Application of Laws Act 2024 |
| 26 December 2024 | Six Acts deemed to have come into operation: Companies Act 2025 (No. 1 of 2025), Customs Act 2025 (No. 2), Employment Act 2025 (No. 3), Employment of Foreign Workforce Act 2025 (No. 4), Financial Services Act 2025 (No. 5) and Income Tax Act 2025 (No. 6, subject to s. 1(3)). Application of Laws (Amendment) Act 2025 (No. 7 of 2025) commences, deleting Schedule A items replaced by GMC Acts and inserting s. 5A and Schedule C (Bhutan sales tax laws). | Each Act, s. 1; Amendment Act 2025 |
| 1 November 2025 | Engagement of a GMCA-empanelled Corporate Service Provider (CSP) becomes mandatory for all new company incorporations through GCRO. Four CSPs empanelled: two full, two provisional (100% Bhutanese-owned companies only). | GCRO |
| 2026 | Business Names Registration Act 2026 (No. 1 of 2026), Limited Liability Partnerships Act 2026 (No. 2), Limited Partnerships Act 2026 (No. 3) and Partnership Act 2026 (No. 4) enacted and listed on gmc.bt/legislation. | gmc.bt/legislation |
| 30 April 2026 | GCRO waiver of the resident director / resident authorised representative and registered office requirements ends. Registrar may revoke registration of non-compliant companies and branches; registered office to be filed within one month of incorporation. | GCRO |
| 7 May 2026 | GFSO General Rulebook (GEN) 2026, Version 1.0, dated 07052026, published: Principles (Ch. 2), systems and controls (Ch. 3), location of offices (4.5), licence applications (5.2), mandatory appointments (5.5), change of control (8.8), Representative Offices (Ch. 9). | GEN Rulebook 2026 |
| 15 June 2026 | Sale of Goods Act 2026 (No. 5 of 2026) comes into operation (s. 63). Unfair Contract Terms Act 2026 (No. 6 of 2026) comes into operation (s. 30); it does not apply to contracts made before that date. Application of Laws (Amendment) Act 2026 (No. 7 of 2026) operative, deleting Schedule A items 15 and 18. | SoGA s. 63; UCTA s. 30; Amendment Act 2026 |
| June 2026 | GCRO publishes its current registry practice: fee schedule (private company US$2,000 registration and renewal; guarantee company US$500/US$250; branch US$2,000/US$2,000; sole proprietorship US$250/US$125; special UEN US$3,000); about one week processing; US$1 minimum paid-up capital; DNFBP registration list; GMCA contact emails. | GCRO |
Watch list: Income Tax Act 2025 provisions awaiting Gazette commencement
Section 1(3) of the Income Tax Act 2025 provides that the following provisions "come into operation on a date that the designated officer appoints by notification in the Gazette"; s. 1(4) allows different dates for different provisions. None is operative until then.
| Provision | Subject |
|---|
| s. 10H | Securities lending or repurchase arrangements |
| s. 10I | Additional Tier 1 capital instruments |
| s. 10K | Covered bond transactions |
| s. 10L | Gains from the sale of foreign assets |
| s. 13(1)(a), (aa), (b), (ba), (bb), (bc) | Specified exempt income categories |
| s. 13D | Income of prescribed persons from funds managed by a GMC fund manager |
| s. 13F | Exemption of income of foreign trust |
| s. 13L | Foreign account of philanthropic purpose trust |
| s. 13M | Asset securitisation |
| s. 13N | Prescribed locally-administered trust |
| s. 13O | Company incorporated and resident in GMC arising from funds managed by a GMC fund manager |
| s. 13OA | Partners of a limited partnership, funds managed by a GMC fund manager |
| s. 13R | Not-for-profit organisations |
| s. 13T | Eligible family-owned investment holding company |
| s. 13U | Funds managed by a fund manager in GMC (prescribed persons) |
| s. 13V | Sovereign funds and similar |
| s. 37O | Deduction for acquisition of shares of companies |
| s. 43E | Finance and treasury centre concessionary rate |
| s. 43H | Concessionary rate for income from debt securities |
| s. 43R | Approved insurance brokers |
| s. 43V | Managing an approved venture company |
| s. 45(9)(a)–(b); s. 45A(2), (2B), (2C) | Specified withholding sub-provisions |
| s. 50A | Unilateral tax credits |
| s. 108 and Seventh Schedule | Advance rulings by the Comptroller |
Fixed dates already in the statute
| Date | Effect | Section |
|---|
| 31 December 2025 | End of the first-period share disposal exemption window; disposals on or after 1 January 2026 fall under s. 13W(1A). | Income Tax Act 2025, s. 13W(1), (1A) |
| 31 December 2030 | Last day for 0% rate on chargeable income of non-citizen individuals and non-resident Bhutanese citizens. | s. 43(1)(b), (ba) |
| 31 December 2030 | Last day on which a founders company may be approved. | s. 13Y(5) |
| 31 December 2030 | Last day on which a strategic and development company may be approved. | s. 43D(4) |
Series articles that track these developments
- Which Law Applies in GMC? — the Application of Laws Act 2024 and its 2025 and 2026 amendments.
- Commercial Contracts in GMC — the 15 June 2026 commencement and the pre-commencement carve-out.
- Advance Rulings from the GMC Comptroller — what s. 108 will provide when commenced.
- The Section 13O, 13OA and 13U Fund Exemptions — the fund regime awaiting commencement.
- The Twelve Principles for Licensed Firms — the GEN Rulebook v1.0 in practice.
Frequently asked questions
Why are the 2025 Acts dated before they were numbered?
Each is "deemed to have come into operation on 26 December 2024" by its own commencement section, while carrying a 2025 law number.
Can I rely on s. 13T or s. 13O today?
No. Both are listed in s. 1(3) and commence only on Gazette notification. Structures can be prepared, but the exemption is not operative until then.
Does the Unfair Contract Terms Act affect my existing contracts?
No. It does not apply to contracts made before 15 June 2026 (s. 30). Later contracts are subject to the reasonableness test in s. 11.
How often is this tracker updated?
Whenever an instrument is added to gmc.bt/legislation, a GFSO rulebook version changes, a Gazette notification commences a listed provision, or GCRO revises its published registry practice. Fees and levy rates are recorded when published and revised from time to time.
You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.
References
- Royal Charter No. 1 of 2024, Arts. 1, 3, 4
- Application of Laws Act 2024, ss. 3, 4, 5, 5A, 11, Schedules A–C; Application of Laws (Amendment) Acts 2025 and 2026
- Companies Act 2025, Customs Act 2025, Employment Act 2025, Employment of Foreign Workforce Act 2025, Financial Services Act 2025: s. 1 (commencement)
- Income Tax Act 2025, ss. 1(3), 1(4), 13W, 13Y(5), 43(1)(b), 43(1)(ba), 43D(4), 108
- Sale of Goods Act 2026, s. 63; Unfair Contract Terms Act 2026, ss. 11, 30
- GEN Rulebook 2026 (v1.0, 7 May 2026)
- GCRO FAQ for GMCA Entities (3 June 2026, v0.2), Gelephu Corporate Registration Office
