CBDT Clarifies Reporting Norms for Sovereign Wealth Funds Under IT Act 2025

Last updated: 01 April 2026


The Central Board of Direct Taxes (CBDT) has issued Circular No. 03/2026 dated March 30, 2026, introducing a structured compliance and reporting mechanism for Sovereign Wealth Funds (SWFs) under the Income-tax Act, 2025.

The circular lays down procedures for notification, application, and ongoing reporting requirements, aiming to streamline tax exemptions available to foreign sovereign investors in India’s infrastructure sector.

CBDT Clarifies Reporting Norms for Sovereign Wealth Funds Under IT Act 2025

Key Highlights of CBDT Circular 03/2026

1. Tax Exemption Framework for SWFs

Under Schedule V of the Income-tax Act, 2025, eligible SWFs can claim tax exemption on:

  • Dividend income
  • Interest income
  • Certain specified sums
  • Long-term capital gains

These benefits apply to investments made in specified infrastructure businesses between April 1, 2020 and March 31, 2030, provided the investment is held for at least three years.

2. Mandatory Application Process - Form I

CBDT has introduced Form I as the standard application format for SWFs seeking notification.

  • Must be filed with the CBDT authority handling foreign tax matters
  • Requires detailed disclosures including:
    • Country of residence
    • Tax Identification Number (TIN)
    • Legal structure and supporting documents

3. Quarterly Reporting Requirement - Form II

All notified SWFs must now:

  • File a quarterly statement (Form II)
  • Submit within one month from the end of each quarter
  • Report details of every investment made during the period

Additionally, SWFs must:

  • File income tax returns
  • Submit audit reports

4. Two Categories of SWFs Defined

Category I: Already Notified SWFs

  • No need to file Form I again
  • Must comply with quarterly reporting via Form II

Category II: New Applicants

  • Required to:
    • Submit Form I for notification
    • File Form II quarterly after approval

5. Digital Filing & System Oversight

The CBDT has assigned the Director General of Income-tax (Systems) to:

  • Define data standards and filing procedures
  • Ensure secure submission and data management
  • Enable electronic compliance infrastructure

6. Effective Date

The new framework will come into force from: April 1, 2026
Applicable from Tax Year 2026-27 onwards

Impact on Investors and Infrastructure Sector

This move is expected to:

  • Enhance transparency in foreign investments
  • Strengthen compliance monitoring
  • Facilitate smoother entry for global sovereign funds
  • Boost infrastructure financing in India

By standardizing reporting and application processes, the government aims to create a more investor-friendly yet accountable tax regime.


CCI Pro

Category Income Tax   Report

  72 Views

Comments



More »