Evolution of Special Tax Regimes for Offshore Funds : Clause 208 of the Income Tax Bill, 2025 Vs. Section 115AB of the Income-tax Act, 1961

Taxation of offshore fund income: concessional rates for unit income and segregated treatment to prevent double deductions.

Clause 208 establishes a special tax regime for overseas financial organisations investing in units purchased in foreign currency: concessional rates apply to income from such units and to long term capital gains, other income is taxed at normal rates with aggregation across heads, deductions are disallowed where gross total income consists solely of such concessional income while in mixed income cases concessional income must be segregated and deductions allowed only against the non concessional portion, and eligibility requires specified investment arrangements with prescribed Indian institutions plus SEBI approval with ''unit'' defined by cross reference to the schedule or UTI.