- Section 9A (Investment Fund Participation Rules):
- Indirect investments by Indian residents in offshore funds are now excluded from the 5% limit, reducing compliance burdens .
- The Central Government can relax conditions for eligible investment funds/fund managers in International Financial Services Centres (IFSCs) .
- Section 10(4D) (Tax Exemptions for Specified Funds):
- Retail Schemes and Exchange-Traded Funds (ETFs) regulated under IFSCA (Fund Management) Regulations now qualify for tax exemptions .
- Funds must comply with IFSCA regulations instead of additional CBDT-prescribed conditions .
- Section 47(viiad) (Tax-Neutral Relocation of Funds):
- Expands the definition of “resultant fund” to include Retail Schemes and ETFs, allowing tax-free relocation to IFSCs without meeting Section 10(4D) conditions .
- Section 10(4E) (Exemptions for Non-Residents in IFSCs):
- Extends tax exemptions to non-residents trading in offshore derivative instruments and OTC derivatives with Foreign Portfolio Investors (FPIs) in IFSCs .
- Section 10(10D) (Life Insurance Policies in IFSCs):
- Corrects the reference from “IFSC insurance intermediary offices” to “IFSC insurance offices” for tax-exempt life insurance policies .










