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The Union Budget for FY27 introduces a game-changing safe harbour regime for non-residents warehousing components in bonded facilities linked to just-in-time logistics. Starting April 1, this proposal will enable a 2 per cent profit margin on invoice value, translating to an effective tax of 0.7 per cent, lower than the effective rate of around 1 per cent cited for rival hubs like Vietnam, according to Finance Ministry sources.
In her Budget speech in Parliament, Finance Minister Nirmala Sitharaman announced a proposal to provide safe harbour to non-residents for component warehousing in a bonded warehouse at the per cent profit margin of the invoice value, in order to harness the efficiency of just-in-time logistics for electronic manufacturing.
"The resultant tax of about 0.7 per cent will be much lower than in competing jurisdictions," she said.
According to sources, what makes the proposal attractive is its ability to deliver a globally competitive tax outcome that can be lower than the 1 per cent effective tax often cited for Vietnam and similar hubs. "This also offers much higher certainty on transfer pricing and audit exposure. Unlike 'low-tax' jurisdictions where benefits can be conditional on incentives, substance tests, or periodic renegotiations, a codified safe harbour typically reduces litigation risk, compliance friction, and time-to-decision for MNC supply chains," said one of the sources.
"This certainty matters for manufacturers because warehousing/parts staging is a high-volume, low-margin function. Hence predictable, low taxation plus fewer disputes can be worth more than a headline incentive," noted the source.
Finance Ministry sources also say that on a net-net basis, India can offer a comparable-or-better post-tax cost with lower regulatory risk, making the overall proposition stronger than a marginally higher effective rate elsewhere.