CBDT floats draft notification with regard to renumeration of fund managers

The tax department has come out with a draft notification with regard to renumeration of India-based fund managers who are managing funds of overseas investors.

Section 9A of the Income-tax Act, 1961, provides for a special taxation regime in respect of certain offshore funds in the context of their fund managers being located in India, an official said.

It is provided that in case of an eligible investment fund, the fund management activity carried out through an eligible fund manager acting on behalf of such fund shall not constitute business connection in India of the said fund, the Central Board of Direct Taxes said.

Finance (No 2) Act, 2019 with effect from April 1, 2019, amended section 9A so as to provide that the remuneration paid by the fund to an eligible fund manager in respect of fund management activity undertaken by him on its behalf is not less than the amount calculated in such manner as may be prescribed, it said.

Accordingly, the manner for calculation of the amount, compared to which the remuneration paid to the eligible fund manager should not be less, is required to be prescribed, it added.

The CBDT has sought inputs from stakeholders on draft notification proposing amendments December 19.