Notification of Sovereign Wealth Fund under section 10(23FE) of the Income-tax Act, 1961

Last updated: 23 July 2020

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This notification introduces tax exemptions for Sovereign Wealth Funds (SWFs) investing in specified infrastructure businesses in India. The exemption applies to income like dividends, interest, and long-term capital gains made between April 1, 2020, and March 31, 2024, provided the investment is held for at least three years. To apply for this status, SWFs must submit an application in Form I to the Central Board of Direct Taxes (CBDT).

Circular No. 15 of 2020 F No 370142/26/2020-TPL Government 0 f India Ministry of Finance Department of Revenue Central Board of Direct Taxes (Tax Policy Legislation Division) New Delhi, 22nd July, 2020 Notification of Sovereign Wealth Fund under section to(23FE) of the

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FAQ :

This notification provides for tax exemption to Sovereign Wealth Funds (SWFs) on certain incomes arising from investments made in specified infrastructure businesses in India.

Income in the nature of dividend, interest, or long-term capital gains arising from investments made in specified infrastructure businesses is eligible for exemption.

Investments must be made during the period from 01.04.2020 to 31.03.2024, and the investment must be held for at least three years.

Specified persons include wholly owned subsidiaries of Abu Dhabi Investment Authority (ADIA), notified Sovereign Wealth Funds (SWFs), and notified Pension Funds (PFs) that meet the specified conditions.

SWFs must file an application in Form I, as provided in the Annexure to the circular, with the Member (Legislation), Central Board of Direct Taxes (CBDT).

Initially, the application should be submitted to the Member (Legislation), CBDT, Department of Revenue, Ministry of Finance, New Delhi, during the financial year 2020-21. Subsequently, it should be submitted to the Member, CBDT, overseeing the Foreign Tax and Tax Research Division.