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GIFT City Category III AIFs vs FIFs for Family Offices

19 April 20251 min read
BANKING & FINANCEGIFT City CategoryIII AIFs vs FIFs forFamily Offices19 April 2025safalsetu.com

Why in the news

Family offices are leaning toward Category III Alternative Investment Funds in GIFT City rather than Family Investment Funds (FIFs), thanks to clearer and kinder tax rules.

Key facts

  • Of seven Indian family offices seeking FIFs last year, just two won in-principle clearance from the IFSCA.
  • The FIF route is not approved for domestic family offices wanting to invest abroad; offshore entities are allowed but with little take-up.
  • Earlier, FIFs investing in public markets faced the FPI tax regime, with higher tax on capital gains, debt and derivatives.
  • Recent IFSCA amendments clarified the tax position and favoured AIFs.

Category III AIF advantages

  • Possible access to the Specified Fund regime.
  • No capital gains tax on debt and derivatives.
  • 10% tax on dividends and interest.
  • Attracts non-resident Indian family offices wanting Indian public markets.

Growth in GIFT City

MeasureEarlierDecember 2024
Category III AIF schemes50 (Dec 2023)116
Investments$800 million$2 billion
Total commitments$1.67 billion (previous year)$4.7 billion

About FIFs

  • A purpose-built vehicle through which one family office, or a family-controlled group, manages its money and invests worldwide.

Why interest is rising

  • Middle East family offices want to diversify into India and other emerging markets given high U.S. valuations.
  • GIFT City exempts derivatives income from tax.
  • Domestic family offices increasingly use broad-based AIFs in GIFT City for overseas investing, helped by liberalised norms.

Exam angle

  • Regulator for GIFT City: IFSCA.
  • Fund types: Category III AIF versus FIF.
  • Tax rate on dividends and interest: 10%.

Test yourself

1. Which regulator oversees GIFT City and issued the amendments that clarified the tax regime for AIFs?

The International Financial Services Centres Authority made the changes.

2. A Category III AIF in GIFT City under the Specified Fund regime may pay what tax rate on dividends and interest?

The regime offers a 10% rate on dividends and interest.

3. How many Category III AIF schemes operated in GIFT City by December 2024?

The count rose from 50 in December 2023 to 116.