Fund Tax FAQs
Short answers to the questions investors and fund managers ask most, each with the provision it rests on.
Does every GIFT IFSC fund give tax-free returns?
No. Only a fund that qualifies as a specified fund gives its unit holders that treatment, and a fund qualifies only if its units (other than the sponsor’s or manager’s) are held by non-residents, with a limited exception. A GIFT IFSC fund that takes Indian residents is taxed as a trust.
Law: Schedule VI, Sl. 9 and Note 1(g)(C)
If the fund deducts tax, is that the end of it?
Not necessarily. Tax deducted at source is an advance. A resident with a ₹5,00,000 long-term gain from a Category II fund owes ₹65,000 (12.5% plus 4% cess); the fund deducts ₹50,000 (10%), leaving ₹15,000 to pay with the return.
Law: Section 224; section 393, Table Sl. 4(iii)
Does the fund manager’s tax treatment decide the investors’?
No. The fund manager, the fund and the investors are separate taxpayers. A deduction available to an IFSC fund management company reduces its own taxable income only; it does not make the investors’ returns tax-free.
Law: Section 147
Is a resident investor treated like a qualifying non-resident?
No. The specified-fund exclusion is built on non-resident unit holders. Residents generally cannot be admitted without the fund losing that status, apart from investors who become resident later, up to 5% of the units and subject to prescribed conditions.
Law: Schedule VI, Note 1(g)(C)
Can a fund manager deduct 100% of every kind of income?
No. The deduction covers income from the approved business activities of the IFSC unit. Income from anything else falls outside it. The deduction also runs only for the period the section allows: for an IFSC unit, 20 consecutive tax years out of 25, at its option.
Law: Section 147(2)(b) and (3)
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Meet the expert
CS Prashant Kumar
Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker
Published in The Chartered Accountant (Jun 2025, Jan 2025, Mar 2024) and Chartered Secretary (Aug 2023)
Prashant Kumar is a seasoned Company Secretary and corporate governance strategist with more than 13 years of experience advising large corporates, promoter-led groups and global businesses on compliance, regulatory risk and board governance. In GIFT IFSC, the IFSCA regime is his day job rather than a research topic.