Clarification regarding taxability of income earned by a non-resident investor from off-shore investments routed through an Alternate Investment Fund

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..... Central Board of Direct Taxes North Block, New Delhi Dated: 3 rd July, 2019 Subject: Clarification regarding taxability of income earned by a non-resident investor from off-shore investments routed through an Alternate Investment Fund-reg. In the context of Alternate Investment Funds (AIFs), refer .....

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..... I-FB contains special provisions relating to tax on income of investment funds and income received from such funds. Under Chapter XII-FB, section 115UB of the Act ( 'Tax on income of investment fund and its unit holders' ) is the applicable provision to determine the income and tax-liability of investment funds their investors. In this context, investment fund is defined in E .....

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..... unit holder of an investment fund, out of investments made in the investment fund, shall be chargeable to income-tax in the same manner as if it were the income accruing or arising to, or received by such person had the investments made by the investment fund been made directly by him and not through the AIF. 5. The matter has been considered by the Board. As section 115UB(1) of the .....

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