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India witnesses a considerable amount of foreign investment from Foreign Portfolio Investors (FPI). The vast array of securities in which FPIs can invest in, coupled with the ease of the regulatory framework, has made the FPI route a suitable mode of foreign investment in India.

Given the large number of transactions undertaken by FPIs on a daily basis, efficiency in tax costs and tax compliances are imperative factors for FPIs while undertaking investments in India.

We offer a wide range of services to our FPI clients, including:

  • Advising on suitable investment structure for setting up the FPI for investment in India, including jurisdictional analysis and assistance in implementing the identified investment structure;
  • Advising on whether the FPI is eligible to claim the relevant tax treaty benefits;
  • Assisting in preparing the Indian tax chapter of the Private Placement Memorandum (PPM) or a similar document of an FPI;
  • Advising on the tax implications (including the implications of indirect transfer provisions) in the case of reorganizations undertaken outside India;
  • Determining the eligibility criteria for registration as an FPI and assistance in obtaining the registration by liaising with the Designated Depository Participant;
  • Assisting in obtaining a Permanent Account Number (PAN);
  • Providing on-going tax compliance services which, inter alia, include issuing tax certificates for remittance of funds outside India;
  • Assisting in preparing and filing the annual return of income; and
  • Providing tax litigation assistance, including representation services.

For an overview of the Indian tax and regulatory framework applicable to FPIs, we request you to refer to our Dhruva brochure.