Hydropower anchors the Gelephu Mindfulness City's Green Energy and Technologies pillar, and the sovereign bitcoin mining built on it is evidence that the power is dispatchable at industrial scale. Around it sit data centres, compute, battery and grid technology, and industrial processes that need clean power in volume: large capital projects with long payback periods, which is what the strategic and development company concession is designed for. Basnet Law Pte. Ltd., the first law firm incorporated in the Gelephu Mindfulness City, advises developers, operators, lenders and technology providers under the Income Tax Act 2025, the Customs Act 2025 and the Financial Services Act 2025. This page explains what the framework provides and how we run a project through it.
How we help
- Framing the expression of interest to the Green Energy and Technologies pillar, the first gate in registration.
- Structuring the project vehicle through a GMC company, LLP or limited partnership, with the resident director in place.
- Site, power and connection terms negotiated through the Economic Development Group.
- Strategic and development company applications for a rate of not less than 5%, or founders company applications where the activity is new to GMC at scale, before the 31 December 2030 cut-off.
- Capital allowances on plant, the 100% election for computers and prescribed automation equipment, and intellectual property allowances.
- Customs treatment of imported turbines, rigs, servers and batteries.
- Renewable energy certificates and carbon credits as environmental instruments, and the perimeter for compute businesses that mine.
What the GMC framework provides for green energy and technologies
GMC lists Green Energy and Technologies among its eight priority industries, and the Royal Charter gives the Authority powers that include fiscal, customs and tariff benefits, licences and funds. Grid connections, tariffs and power purchase terms for a large industrial load are commercial matters negotiated with the Economic Development Group. Land follows the same route: the Economic Development Group offers flexible long-term leases, and the lease itself sets term, use, milestones and termination.
The Income Tax Act 2025 charges companies at 15% on chargeable income. The concession most likely to fit this pillar is the strategic and development company route: the designated officer may approve a company for a specified business where satisfied it is expedient in the public interest, and the letter of approval fixes a rate of not less than 5%, the qualifying business, the start date and a relief period that with extensions cannot exceed 20 years. The Act sets no sector restriction and no fixed criteria. The founders company exemption is the alternative where the industry is not carried on in GMC at adequate scale, capped at 15 years. Neither approval may be granted after 31 December 2030, and both require separate accounts for any other business.
Capital expenditure on machinery or plant attracts an annual allowance of 33⅓%, and a taxpayer that installs a computer or other prescribed automation equipment for its trade may elect a 100% allowance instead; whether a particular rig or server qualifies is for the Comptroller. Capital expenditure on acquiring intellectual property rights is written down over 5, 10 or 15 years by election, and interest on an approved foreign loan for productive equipment can be exempted or taxed at a concessionary rate. Imported hardware enters under the Customs Act 2025, where duty rates are set by Gazette order and exemptions granted by order or individual direction.
Two perimeter questions arise under the Financial Services Act 2025. Renewable energy certificates and carbon credits recognised by the Regulator are environmental instruments and so specified investments; dealing in or arranging them by way of business is regulated, with an exclusion to test for a generator selling certificates alongside its power. And mining or validating with an operator's own equipment and tokens is not a listed regulated activity, but selling the output can amount to dealing as principal, and holding or managing other people's tokens is custody or asset management; the Gelephu Financial Services Office decides any licence.
Who this is for
- Renewable energy developers and independent power producers.
- Data centre, compute and green mining operators seeking hydropower.
- Battery, grid and industrial technology projects needing clean power.
- Lenders and investors financing GMC energy and infrastructure assets.
- Equipment suppliers and EPC contractors.
How an engagement runs
- Feasibility. We test pillar fit, entity choice and whether the strategic and development company rate or the founders exemption is realistic.
- Site and power. We open the Economic Development Group engagement and negotiate lease, connection and power terms until the site is secured.
- Incentive filing. We prepare the written application with the prescribed particulars and the public-interest case and follow it to the letter of approval.
- Contracts and finance. We draft EPC, O&M, offtake and financing documents and register security with the Registrar in time.
- Operations. We confirm the customs position before hardware ships, document the allowance elections and settle any perimeter question with the Regulator.
Frequently asked questions
Does an energy project pay 0% tax in GMC?
Not as of right. The company rate is 15%. A strategic and development company pays a negotiated rate of not less than 5% for up to 20 years, and a founders company in an approved founders industry is exempt for up to 15 years. Both are granted on approval and close to new approvals on 31 December 2030.
Are power tariffs and grid terms fixed by law?
Tariffs, lease terms and connection timelines are negotiated with the Economic Development Group and set in the lease and power agreement.
Is a data centre or mining operation regulated by GFSO?
Mining and validating with your own equipment and tokens is not a listed regulated activity. A licence question arises if sales of output amount to a dealing business, or if the operator holds, manages or pools other people's assets.
Can imported equipment come in duty free?
The Customs Act 2025 lets the designated officer exempt classes of goods or persons by Gazette order or individual direction, with rates set by Gazette order. We confirm the position before the goods ship.
Talk to GMC counsel on the ground
Basnet Law Pte. Ltd. is the first law firm incorporated in the Gelephu Mindfulness City. A short conversation early in a matter usually saves time and cost later. Write to basnet@basnetgmc.com or office@basnetgmc.com with a few lines about your plans, and we will tell you plainly what is needed, how long it takes, and whether we are the right fit.
You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.
