The Central Board of Direct Taxes (CBDT) has relaxed the requirement of remunerating fund managers of certain offshore funds because of the amended Rule 10V for availing the special taxation regime under Section 9A.

The Section provides for a special taxation regime in respect of certain offshore funds in the context of their fund managers being located in India.


The CBDT has stated that for financial years 2019-20 and 2020-21 in cases where the remuneration paid to the fund manager is lower than the amount of remuneration prescribed under sub-rule (12) of Rule 10V, but is at arm’s length, there is no need to take CBDT nod for that lower amount to be the amount of remuneration.