Specified Investments by ADIA, Sovereign Wealth Funds and Pension Funds

The ITA had previously been amended to exempt dividend, interest and long-term capital gains arising from investments made in specified infrastructure businesses in India by: (i) wholly owned subsidiaries of the Abu Dhabi Investment Authority; (ii) notified sovereign wealth funds; and (iii) notified pension funds, subject to certain conditions. On July 6, 2020, the Government issued a notification specifying that investments in the infrastructure sub-sectors mentioned in the Updated Harmonised Master List of Infrastructure Sub-sectors dated August 13, 2018, will be eligible for the aforementioned exemption. The Government has also recently introduced the application forms for the notification of sovereign wealth funds and pension funds with respect to the aforementioned exemption, as well as prescribed certain tax compliance and reporting obligations to be adhered to by such funds.