Offshore fund manager regime clarified: eligibility, arm's length remuneration, documentation and approval under new rules determine tax benefits. Rules for the offshore fund manager regime under section 9A prescribe look-through treatment for institutional investors meeting conditions, due diligence and declaration processes to ascertain Indian participation, and limited grace periods for temporary non-fulfilment of eligibility conditions. Remuneration to fund managers is treated as an international transaction between associated enterprises for arm's-length determination; fund managers must maintain transfer pricing documentation, obtain an accountant's report in Form 3CEJ and furnish annual statements electronically in Form 3CEK. A Board approval process and conditions for withdrawal of approval are provided.