GMC Tax and Incentive Applications: Legal Advisory

The value in GMC's tax regime lies less in the headline rate than in two negotiated incentives whose approval windows are closing, so timing and evidence decide what a business actually pays. The Income Tax Act 2025 gives the Gelephu Mindfulness City Special Administrative Region (GMC) a 15% corporate rate, a 0% rate for non-citizen individuals until 31 December 2030, and two negotiated incentives whose approval windows close on the same date.

Model the effective rate for companies, trustees and non-resident persons, and the individual position.

Advise on founders company and strategic and development company applications.

Advise on structuring groups to use group relief between GMC companies.

Advise on building transfer pricing files that satisfy the arm's length rules and avoid the 5% surcharge.

Advise on share disposal exemptions, amalgamations and the general anti-avoidance rule.

Advise on advance rulings and on the legal issues in returns and Comptroller queries.

Companies relocating or expanding into GMC and modelling their effective rate. Founders in new industries who may qualify for the founders company exemption. Capital-intensive or strategic investors negotiating a concessionary rate. Multinational groups with related-party flows into or out of GMC.