Funds Practice

Alternative Investment Funds (AIFs)

Structuring of the fund from tax and regulatory perspectives including jurisdictional analysis for overseas investors, ‘carry’ structuring for the investment manager, selection of the appropriate investment vehicle, characterisation of income, nuances in trust taxation etc.


  • Providing tax and regulatory advisory/compliance services to investors including obtaining lower TDS certificates

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  • Assisting in setting up an AIF and complying with the regulations applicable therein
  • Drafting and reviewing various documents, viz., trust deed, PPM, agreements etc. from tax and regulatory perspectives
  • Preparing and filing AIF registration application with SEBI
  • Providing compliance, operational and tax manuals
  • Preparing reports, forms, declarations, documents required under AIF regulations
  • Preparing tax return, Form 64C and Form 64D and reviewing the distribution working to be issued to the investors
Private Equity

  • Fund structuring from tax and regulatory perspectives including advising on jurisdiction analysis for fund vehicles, legal form of fund vehicles, carry structuring for the investment manager and structure review from GAAR and POEM perspectives
  • Advising on alternate investment/divestment structure options including foreign investment routes as per the prevailing tax and regulatory regime
  • Advising on capital structure of target company
  • Advising on exit and cash repatriation options from tax and regulatory perspectives
  • Conducting tax due diligence
  • Reviewing agreements such as share purchase/subscription agreement and advising on withholding tax aspects

Foreign Portfolio Investors (FPIs)

  • Obtaining FPI registration from the Designated Depository Participants and registration with the tax office
  • Providing Income-tax advisory services on matters such as investment structuring, jurisdictional analysis, GAAR, indirect transfer, Section 9A, POEM, BEPS (including MLI), availability of treaty benefits etc.
  • Preparing computation of income and tax returns
  • Accounting of daily purchase, sales and capital gains and reconciling quantities in stock and derivatives
  • Issuing remittance certificates and calculating tax liability
  • Representing before the tax authorities for income-tax litigation matters. Liaising with counsel, if required, for making representations before court(s)