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Tax Regime for IFSC Units

The fiscal architecture that makes the IFSC competitive — the income-tax holiday, MAT relief, indirect-tax exemptions, and investor-level reliefs.

Bhatt & Joshi
TAX
Tax Regime for IFSC Units
Free Practitioner Booklet

Tax Regime for IFSC Units — The Practitioner's Booklet

A treatise-grade working reference on the licensing, capital, conduct-of-business and tax framework for Tax Regime for IFSC Units at GIFT IFSC — every conclusion anchored in verbatim statutory and regulatory text.

Download the booklet  → PDF · First Edition · May 2026
Why investors choose GIFT IFSC

The case for Tax Regime for IFSC Units — before the rulebook.

GIFT IFSC competes head-on with Singapore, Dubai and Mauritius — on tax, on currency, and on access to India. Here is what actually moves the decision, before the regulatory detail below.

01

A 20-year tax holiday

100% deduction on business income for any 20 consecutive years in a 25-year block under Section 147 of the Income-tax Act 2025 (Finance Act 2026), then a 15% concessional rate. MAT capped at 9%.

02

US-dollar, offshore by law

An IFSC unit is treated as a person resident outside India under FEMA — raise, hold and transact in USD / EUR / GBP, with full foreign-currency freedom and no rupee-conversion drag.

03

100% foreign & NRI capital

Foreign and NRI investors can hold up to 100% — without the aggregate ownership caps that constrain comparable onshore vehicles.

04

An on-ramp to India

Unlike a purely offshore hub, GIFT IFSC sits on Indian soil and aligns with national policy — an offshore base that is also a door into one of the world's largest growth markets.

05

Zero STT, CTT & stamp duty

IFSC-exchange transactions are free of Securities and Commodity Transaction Tax and stamp duty; services rendered by IFSC units are zero-rated for GST.

06

One regulator, India's rule of law

A single unified regulator (IFSCA) under the IFSCA Act 2019, an independent judiciary, and a treaty-anchored legal order — certainty, not just headline rates.

The opportunity is real, but every benefit carries a condition — and that is where counsel at the threshold earns its place.

What it is

The IFSC tax regime is the thread running through every other head. Under the Income-tax Act, 2025 (in force from 1 April 2026, replacing the 1961 Act), the IFSC unit deduction — historically Section 80LA — is carried forward and, following Union Budget 2026-27, enhanced. It remains a structured incentive, not a blanket exemption, and every benefit carries a condition.

Key features

  • The unit holidayA 100% deduction on business income — historically for 10 consecutive years out of 15 under Section 80LA, and extended by Budget 2026-27 to 20 consecutive years out of 25, with post-holiday IFSC income taxed at a concessional 15%. The deduction requires income in convertible foreign exchange and is claimed via the prescribed form.
  • MAT / AMT reliefIFSC units pay Minimum Alternate Tax / Alternate Minimum Tax at 9% rather than the standard rates; companies under the concessional corporate-tax regime are outside MAT entirely.
  • Indirect taxesNo GST on services to, from, or between IFSC units; no Securities Transaction Tax, Commodities Transaction Tax or stamp duty on IFSC-exchange transactions; customs/import-duty relief on the SEZ side.
  • Investor-level reliefsExemptions for specified-fund income attributable to non-residents, for certain OTC-derivative and offshore-derivative income, and for interest on IFSC banking-unit deposits and qualifying bonds (the old Sections 10(4D)/(4E)/(4F), as carried into the 2025 Act).
  • TDS relief on FME feesCBDT Notification 67/2025 (effective 1 July 2025) removed the 10% withholding on professional, management and similar fees paid to tax-holiday IFSC units, on furnishing the prescribed statement-cum-declaration — a real cash-flow improvement for fund managers.

How we help

Tax is where our GIFT City practice meets the firm's foundational income-tax litigation strength. We advise on structuring to qualify for and preserve the deduction, on the foreign-currency and commencement conditions, on the investor-level reliefs, and — if a position is ever questioned — on representing it before the authorities.

Tax law is moving quickly: the 1961 Act has been replaced by the Income-tax Act, 2025, section numbering has changed, and Budget 2026-27 measures take effect through the Finance Act. Always confirm the current section reference and conditions before acting.
Interactive • Codified from the rules

Check it yourself.

The conditions for this head, turned into a tool you can use now. Indicative only — built to orient your thinking before we map it to your facts.

IFSC tax-holiday estimator

Estimate the indicative shape of the income-tax holiday for an IFSC unit.

$10.0M
25%
22%
30%

Illustration only — not a tax opinion. Deduction historically Section 80LA; carried into the Income-tax Act, 2025 as Section 147 and extended by Budget 2026-27 to 20 consecutive years out of 25, post-holiday income at a concessional 15%. Assumes income in convertible foreign exchange and 100% qualifying.

Indicative tool — not legal or tax advice. Confirm against current IFSCA regulations and your facts.

The numbers

The tax architecture, at a glance

The IFSC tax regime is what makes GIFT City competitive — here is the architecture every investor should price in.

Tax holiday
20 of 25 yrs
100% deduction on business income for 20 consecutive years in a 25-year block (S.147, Finance Act 2026).
MAT / AMT
9%
Minimum Alternate Tax capped at 9% of book profit for IFSC units.
Transaction taxes
Zero
No STT, CTT or stamp duty on IFSC-exchange trades; IFSC services zero-rated for GST.
Post-holiday
15%
A concessional 15% corporate rate after the holiday window.
01
Step 1
Set up the unit
02
Step 2
Elect the window
03
Step 3
Receipts in forex
04
Step 4
Manage MAT
05
Step 5
Post-holiday

Indicative only — not legal advice. Figures and steps are anchored to the applicable IFSCA regulations; confirm the current position before acting.

Watch

Tax Regime for IFSC Units at GIFT IFSC, explained

Overview & opportunity
Video · coming soon
Setup & compliance
Video · coming soon

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