GIFT IFSC Substance Checklist for Fund Managers

A practical self-check of what an IFSC fund management entity should be able to show. It is a checklist, not a legal test.

Tick what you can evidence

The fund management entity has its own office in GIFT IFSC, not only a registered address Its key managerial personnel work from GIFT IFSC Investment and board decisions are taken, and minuted, in GIFT IFSC Fees and costs with related parties are priced at arm’s length and documented Income claimed under section 147 comes only from approved IFSC business activities The deduction period (20 consecutive tax years out of 25) has been tracked from the relevant tax year The accountant’s report required with the return for the deduction is in place

Your checklist

0 of 7 in place

Each unticked item is worth closing before a review or assessment.

How anti-avoidance references work for IFSC entities

Before an anti-avoidance (GAAR) matter goes to the Approving Panel, the Commissioner records satisfaction in Form No. 64. Where the assessee is located in an International Financial Services Centre, the Commissioner seeks a factual report from IFSCA. Real substance in GIFT IFSC is what such a report would look at.

Income-tax Rules, 2026: reference to the Approving Panel

(5) The Commissioner, before making a reference to the Approving Panel under section 274(4), shall,— (a) record his satisfaction regarding the applicability of the provisions of Chapter XI in Form No. 64; and (b) seek specific factual report in writing from the International Financial Service Centre Authority, where the assessee is an entity located in an International Financial Service Centre.

Income-tax Rules, 2026 · text as notified, amendment footnote numbers omitted · checked 24 October 2026 · Official text

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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

13+ years of experienceFCS Fellow member, ICSIAuthor Audit Under Fire

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.

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