GIFT City offers three distinct product structures for global investing. Each serves a different investor profile. Choosing the wrong one means either paying for complexity you do not need or missing out on tax efficiency you are entitled to.
This is a direct comparison of the three structures: mutual funds, PMS, and Category III AIFs.
Structure 1: Retail Mutual Funds
Who owns what: You own units of a pooled fund. The fund manager holds the underlying securities.
How it works: Standard open-ended fund with daily NAV. You subscribe and redeem in USD. The fund manager runs the portfolio.
Minimum: USD 5,000 for most outbound GIFT City MFs.
Tax for residents: LTCG at 12.5% if held over 24 months. STCG at applicable slab rates.
Tax for NRIs: Exempt from Indian capital gains tax (check DTAA with home country for any residency-side obligations).
Lock-in: None for open-ended funds.
Best for: Investors who want straightforward global exposure without complexity. The passive options (PPFAS S&P 500 and Nasdaq 100 FoF) are the lowest-cost, lowest-minimum route to global equities from India.
Live outbound MF options: PPFAS S&P 500 FoF · PPFAS Nasdaq 100 FoF · DSP Global Equity Fund · Edelweiss Greater China Equity Fund · Marcellus Global Equities Fund
Structure 2: Portfolio Management Services (PMS)
Who owns what: You own the underlying securities directly, held in your own demat/custody account at a GIFT City broker.
How it works: The portfolio manager operates under a discretionary mandate (full decision authority) or advisory mandate (recommends, you approve). Your portfolio is individual, not pooled.
Minimum:
- Advisory PMS: USD 25,000 (Phillip Ventures)
- Discretionary PMS: USD 75,000 (Marcellus GCP, PPFAS PPGIS, Phillip Ventures)
Tax for residents: Each buy and sell within the portfolio is a taxable event. You receive a transaction statement and must compute and file your own ITR. LTCG at 12.5% (>24 months), slab rate for STCG.
Tax for NRIs: Each transaction is taxable in India. NRIs must file an ITR if PMS income exceeds the basic exemption. This is the least tax-efficient structure for NRIs.
Lock-in: None at most GIFT City PMS products.
What you get that MFs do not offer: A portfolio built to your specific entry point, direct ownership of named global stocks or ETFs, and a transparent transaction-level audit trail.
Live outbound PMS options: Marcellus GCP · PPFAS PPGIS · Phillip International Pioneer
Structure 3: Category III AIFs
Who owns what: You own units of the fund, not the underlying securities. The structure is pooled, like a mutual fund.
How it works: The fund pools capital from investors and deploys it according to its stated strategy. Category III AIFs can use derivatives, leverage, and complex strategies that retail MFs cannot.
Minimum: USD 75,000 (IFSCA reduced the minimum from USD 150,000 in February 2025 for most products; some older funds still require USD 150,000+).
Tax for NRIs (most important difference): Capital gains inside a Category III AIF are fully exempt from Indian tax for non-resident investors. This is the defining advantage of the AIF structure for NRIs. There is no ITR filing obligation in India if the investor's only Indian income comes from IFSC funds.
Tax for residents: Tax accrues at the fund level. Resident investors receive a post-tax distribution and do not need to track individual transactions. LTCG rate of 12.5% applies at the fund level.
Lock-in: Varies. Some AIFs are close-ended (Mirae Asset Global Allocation Fund, ABSL Global Bluechip), meaning capital is locked for the fund's tenure. Others are open-ended (Baroda BNP GIFT US Small Cap).
Live outbound AIF options: Mirae Asset Global Allocation Fund · Baroda BNP GIFT US Small Cap Fund · ABSL Global Bluechip Equity Fund
Direct Comparison Table
| Mutual Fund | PMS | Category III AIF | |
|---|---|---|---|
| Ownership | Fund units | Direct securities | Fund units |
| Min. investment | USD 5,000 | USD 25,000-75,000 | USD 75,000+ |
| LTCG for residents | 12.5% (>24 months) | 12.5% (>24 months) | 12.5% at fund level |
| Tax for NRIs | Exempt (check DTAA) | Taxable, ITR required | Fully exempt |
| Lock-in | None (open-ended) | None (typically) | Varies (some close-ended) |
| Liquidity | Daily (open-ended) | Within days | Varies |
| Customisation | None | High (PMS) | None |
| Complexity | Low | Medium | Medium-High |
| ITR filing (NRI) | Not required | Required | Not required |
Which Structure Fits Which Investor
You should consider a mutual fund if:
- You are a first-time investor in global equities
- Your investment size is USD 5,000-50,000
- You want passive index exposure (S&P 500, Nasdaq 100)
- You prefer simplicity over customisation
- You are a resident Indian or NRI who wants clean, low-paperwork global exposure
You should consider PMS if:
- You want a dedicated portfolio manager running a named strategy on your behalf
- Your investment size is USD 75,000 or more (USD 25,000 for advisory)
- You want direct ownership and full transparency into individual positions
- You are a resident Indian comfortable with annual ITR reporting on individual transactions
- You want active stock-picking with a specific mandate (quality global compounders, value, thematic ETFs)
You should consider a Category III AIF if:
- You are an NRI or foreign national and want zero Indian tax on capital gains
- Your investment size is USD 75,000 or more
- You are comfortable with a pooled structure and possible lock-in period
- You want exposure to strategies not available in retail MF format (leveraged, ETF-of-ETFs, thematic)
A Note on LRS for Resident Indians
All three structures are accessible to resident Indians via LRS (Liberalised Remittance Scheme), up to USD 250,000 per financial year. The 20% TCS on LRS remittances above INR 10 lakh is a cash flow item, not a permanent tax cost. It is credited against your income tax liability and refunded if you have lower liability.
For resident Indians, the choice between MF, PMS, and AIF is primarily about investment size and complexity preference. Tax treatment differences are minor compared to the NRI scenario.
If you are evaluating which structure fits your situation, speak to Tequity. The decision depends on your tax residency, investment size, and what you want the portfolio to actually do.