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Direct Tax Code / Income Tax

IFSC Finance Company Tax Provisions — Eligible Activities Under Section 177

A comprehensive guide to IFSC finance company tax provisions under Section 177 of the Income Tax Act, 2025, covering eligible activities and compliance requirements.

25 Jul 20263 min read

Finance companies located in International Financial Services Centres enjoy special tax treatment under the Income Tax Act, 2025. Section 177 and Rule 126 specify the eligible activities and conditions for this favourable treatment. Understanding these provisions is essential for finance companies operating in IFSCs.

The Statutory Framework

Section 177

Section 177 provides that the limitation on interest deduction in certain cases shall not apply to a Finance Company located in any International Financial Services Centre, subject to conditions.

Rule 126

Rule 126 specifies the eligible activities for a finance company located in an International Financial Services Centre.

Eligible Activities

Core Activities

A finance company located in an IFSC may only carry out one or more of the following activities:

Lending Activities:

  • Lending in the form of loans, commitments, and guarantees
  • Credit enhancement
  • Securitisation
  • Financial lease

Factoring and Forfaiting:

  • Factoring and forfaiting of receivables

Treasury Centre Functions:

  • Borrowings
  • Lending
  • Hedging of currency or commodity risk
  • Investments
  • Cash management
  • Structured credit
  • Intra-group financing
  • Financial budgeting
  • Similar treasury services and activities

Conditions

Foreign Currency Borrowing

The interest being paid by such finance company, being the borrower, in respect of any debt issued by a non-resident, shall be in foreign currency. This ensures that the IFSC finance company is engaged in genuine cross-border financial activities.

Registration

The finance company must be registered under the International Financial Services Centres Authority (Finance Company) Regulations, 2021.

Business Operations

The finance company must be located in an International Financial Services Centre and must satisfy such conditions and carry on such activities as may be prescribed.

Tax Benefits

Interest Deduction

The limitation on interest deduction under Section 177 does not apply to IFSC finance companies, allowing for greater flexibility in financing arrangements.

Exemptions

Income from certain activities of IFSC units may be exempt under Schedule VI of the Act.

Compliance Requirements

Registration

  • Obtain registration under IFSCA regulations
  • Maintain valid registration throughout operations

Documentation

  • Maintain records of all activities
  • Document compliance with conditions
  • File required returns

Reporting

  • File tax returns on time
  • Report income from eligible activities separately
  • Maintain transfer pricing documentation

Expert Legal Guidance

Understanding IFSC finance company provisions is essential for entities operating in IFSCs. Anuj Desai & Associates provides expert advisory services on IFSC tax compliance, helping finance companies structure their operations to maximise benefits.


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