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Tax Planning

How India’s IFSC Units Can Optimize TDS Exemptions Under Sec 147

Unlocking tax benefits for IFSC-Units: eligibility, documentation & planning under India's latest CBDT TDS exemption rules.

By NomadicTax Research Team · 5-8 min read

Overview

In July 2026, the Central Board of Direct Taxes (CBDT) issued Notification No. 80/2026 under F. No. 275/19/2026-IT(B), declaring that specified payments like interest, dividends, professional fees, brokerage, and financial-service-related income received by eligible IFSC Units shall be exempt from TDS (Tax Deducted at Source) under the new Income-tax Act, 2025. (incometax.gov.in)

Here’s how IFSC Units and their payers can take advantage of this change — and where care is needed.

Who qualifies as an IFSC Unit – and what payments are covered?

FeatureDetails
Eligible UnitUnit registered in an International Financial Services Centre (e.g. GIFT IFSC), and opted to claim deduction under Section 147 for 10 consecutive tax years out of 15. (incometax.gov.in)
Covered PaymentsInterest, dividends, professional & brokerage fees, commission and other financial-service related income. (incometax.gov.in)
Not Deducted by Payer (TDS Nullified)The payer must receive from the IFSC Unit a valid Form No. 1-New-28 (statement-cum-declaration) to avoid deducting TDS. (incometax.gov.in)

Practical steps for IFSC Units

  1. Verify registration and eligibility: Ensure registrations are valid, and the plan to claim Section 147 benefits for 10 out of the next 15 years is documented.
  2. Form 1-New-28 submission: Submit this statement-cum-declaration to each payer of income. Without this, payer must still deduct TDS. (incometax.gov.in)
  3. Maintain proper records: Keep proof of payments, forms submitted, and documentation supporting the 10-year election.
  4. Coordinate with payers: Payers should be aware of the requirement; sometimes they may request clarifications or attach conditions.

What payers should do differently

  • On receiving Form 1, record it properly and set internal processes so they do not deduct TDS on covered payments.
  • Ensure that the nature of services fits within the specified kinds listed.
  • Retain Form 1 record in case of audit or review.

Examples

Example 1: An IFSC unit providing financial advisory services receives ₹10 lakh as professional fees. It has submitted a valid Form 1 to the payer. Before this notification, the payer would deduct TDS (say 10%). With the exemption, no TDS will be deducted, freeing up cash-flow.

Example 2: Another IFSC unit hasn’t opted for Section 147 or didn’t provide Form 1. Payer must continue deducting TDS despite notification. The unit loses benefit.

Interplay with other rules & risk points

  • Only those IFSC Units that opted for the 10-out-of-15-year election under section 147 qualify.
  • If eligible income is misclassified, payer may be forced to deduct TDS anyway, with risk of penalties.
  • IFSC Units should verify that they meet the conditions before claiming exemption.

Action Points

  • Check if your entity qualifies, opt in under section 147, and ensure every payer gets Form 1.
  • If you’re a payer, integrate validation steps to verify that Forms 1 are genuine before zero-rating TDS.
  • Update accounting systems so that entries and withholding calculations incorporate these new rules from the effective date.

Takeaway: Eligible IFSC Units in India can significantly improve cash-flow and reduce compliance burden under the latest CBDT TDS exemption rule — but only by ensuring eligibility and keeping documentation tight. With proper coordination, both units and payers gain.

Sources

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