Tax Relief for Non-Residents: Section 10 Amendment on Offshore Derivative Instruments in IFSC



Quick Summary
The government is introducing an amendment to Section 10 of the tax act to further encourage operations within International Financial Services Centres (IFSCs). This amendment will extend tax relief to non-residents on income derived from offshore derivative instruments and similar contracts when entered into with Foreign Portfolio Investors that are IFSC units. This enhanced tax incentive aims to boost activity within IFSCs and will be effective from 1st April 2026.

Amendment of Section 10 related to Exempt income of Non-Residents The existing provisions of clause (4E) of section 10 of the Act provide that any income accrued or arisen to, or received by a non-resident on account of transfer of non-deliverable forward contracts or offshore derivative instruments or over the-counter derivatives, or distribution of income on offshore derivative instruments entered into with an offshore banking unit of an International Financial Services Centre referred to in
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FAQ :

The amendment extends tax exemption to non-residents on income from certain offshore derivative instruments and contracts when they are entered into with Foreign Portfolio Investors that are IFSC units.

Non-residents who engage in transactions involving non-deliverable forward contracts, offshore derivative instruments, or over-the-counter derivatives with IFSC units.

The amendment will take effect from 1st April 2026, applying to the assessment year 2026-27 and subsequent years.

The relief covers non-deliverable forward contracts, offshore derivative instruments, and over-the-counter derivatives.

The amendment aims to further incentivise operations and investment within International Financial Services Centres (IFSCs).




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