MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
NOTIFICATION
New Delhi, the 10th July, 2026
S.O. 3743(E).— In exercise of the powers conferred by section 400(1) read with section 147 of the Income-tax Act, 2025(30 of 2025) (hereinafter referred to as the said Act), the Central Government hereby notifies that no deduction of tax shall be made under the provisions of the said Act as specified in column (4) of the Table below in respect of the payments, as specified in column (3) of the said Table, made by any payer to a person being a Unit of International Financial Services Centre, (hereinafter referred as the payee), as specified in column (2) of the said Table:-
List of payments receivable by a Unit of International Financial Services Centre (IFSC)
TABLE
| Sl. No. | International Financial Services Centre (IFSC Unit) (Payee) | Nature of receipt | Relevant TDS provisions as per Income- tax Act, 2025 |
|---|
| (1) | (2) | (3) | (4) |
| 1. | Banking Unit | Interest income on External Commercial Borrowings /Loans | Section 393(2) [Table: S.No. 17] |
| | Professional fees | Section 393 (1) [Table: S. No. 6(iii)] |
| | Referral fees | Section 393 (1) [Table: S.No. 1(ii)] |
| | Brokerage income | Section 393 (1) [Table: S.No. 1(ii)] |
| | Commission income on factoring and forfaiting services | Section 393 (1) [Table: S.No. 1(ii)] |
| 2. | IFSC Insurance Intermediary office | Insurance commission | Section 393(1)[Table: S.No. 1(i)] |
| 3. | Finance Company | Interest income on External Commercial Borrowings /Loans | Section 393(1)[Table: S.No. 5(ii)&5(iii)]/Section 393(2) [Table: S.No. 17] |
| | Dividend income | Section 393 (1) [Table: S. No. 7] |
| | Commission income on factoring and forfaiting services | Section 393 (1) [Table: S.No. 1(ii)] |
| 4. | Finance Unit | Interest income on External Commercial Borrowings /Loans | Section 393(1)[Table: S.No. 5(ii) &5(iii)] / Section 393(2) [Table: S.No. 17] |
| | Dividend income | Section 393 (1) [Table: S. No. 7] |
| | Commission income on factoring and forfaiting services | Section 393 (1) [Table: S.No. 1(ii)] |
| 5. | Fund Management entity | Professional fee | Section 393 (1) [Table: S. No. 6(iii)] |
| 6. | Broker Dealer | Dividend | Section 393 (1) [Table: S. No. 7] |
| 7. | Investment advisor | Investment advisory fee | Section 393 (1) [Table: S. No. 6(iii)] |
| 8. | Registered Distributor | Distribution fee and Commission fee | Section 393 (1) [Table: S.No. 1(ii)] |
| 9. | Custodian | Professional fee | Section 393 (1) [Table: S. No. 6(iii)] |
| | Commission fee | Section 393 (1) [Table: S.No. 1(ii)] |
| 10. | Credit rating agency | Credit rating fee | Section 393 (1) [Table: S. No. 6(iii)] |
| 11. | Investment banker | Investment banker fee | Section 393 (1) [Table: S. No. 6(iii)] |
| 12. | Debenture trustee | Trusteeship fee | Section 393 (1) [Table: S. No. 6(iii)] |
| 13. | International Trade Finance Service or “ITFS” | Commission income | Section 393 (1) [Table: S.No. 1(ii)] |
| 14. | FinTech Entity | Technical fee/Professional fee | Section 393 (1) [Table: S. No. 6(iii)] |
| | Commission income | Section 393 (1) [Table: S.No. 1(ii)] |
- (1) For the purposes of this notification,–
(a) “Banking Unit” shall have the same meaning as assigned to it in clause (c) of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Banking) Regulations, 2020;
(b) “broker dealer” shall have the same meaning as assigned to it in clause (g) of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2021 and the provisions of regulations 3, 5, 6 and 7 of the said regulations shall apply to the International Financial Services Centre Unit specified against serial number 6 under column (2) of the said table;
(c) “credit rating agency” shall have the same meaning as assigned to it in clause (j) of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2021 and the provisions of regulations 3, 5, 6 and 7 of the said regulations shall apply to the International Financial Services Centre Unit specified against serial number 10 under column (2) of the above table subject to registration of such credit rating agencies by the International Financial Services Centres Authority;
(d) “custodian” shall have the same meaning as assigned to it in clause (l) of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2021 and the provisions of regulations 3, 5, 6 and 7 of the said regulations shall apply to the International Financial Services Centre Unit specified against serial number 9 under column (2) of the said table;
(e) “debenture trustee” shall have the same meaning as assigned to it in clause (m) of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2021 and the provisions of regulations 3, 5, 6 and 7 of the said regulations shall apply to the International Financial Services Centre Unit specified against serial number 12 under column (2) of the above table subject to registration of such debenture trustee by the International Financial Services Centres Authority;
(f) “Finance Company” shall have the same meaning as assigned to it in clause € of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Finance Company) Regulations, 2021;
(g) “Finance Unit” shall have the same meaning as assigned to it in clause (f) of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Finance Company) Regulations, 2021;
(h) “FinTech Entity” shall have the same meaning as assigned to it in sub-paragraph (i) of paragraph 2 of the International Financial Services Centres Authority’s Circular No. 521/IFSCA/FinTech/FE Framework/2022-23, dated the 27th April, 2022 and paragraph 12 of the said circular shall apply to the International Financial Services Centre Unit specified, against serial number 14 under column (2) of the said table;
(i) “fund management entity” shall have the same meaning as assigned to it in clause (p) of sub regulation (1) of regulation 2 of the International Financial Services Centres Authority (Fund Management) Regulations, 2022 and the provisions of regulations 3, 4 and 5 of the said regulations shall apply to the International Financial Services Centre Unit specified against serial number 5 under column (2) of the said table;
(j) “IFSC insurance intermediary office” shall have the same meaning as assigned to it in clause (s) of sub-regulation (1) of regulation 3 of the International Financial Services Centres Authority (Insurance Intermediary) Regulations, 2021;
(k) “International Financial Services Centre” shall have the same meaning as assigned to it in clause (q) of section 2 of the Special Economic Zones Act, 2005 (28 of 2005);
(l) “International Trade Finance Service” or “ITFS” shall have the same meaning as assigned to it in sub-paragraph (iii) of paragraph 2(B) of the International Financial Services Centres Authority’s Circular No. 388/IFSCA/ITFS platform/2021-22, dated the 9th July, 2021 and paragraph 2€ of the said circular shall apply to the International Financial Services Centre Unit specified against serial number 13 under column (2) of the said table;
(m) “investment adviser” shall have the same meaning as assigned to it in clause (t) of sub-regulation (1) of regulation 2 of the International Financial Services Centres Authority (Capital Market Intermediaries) Regulations, 2021 (except the persons covered under proviso to clause (f) of sub-regulation (1) of regulation 3), and the provisions of regulations 3, 5, 6 and 7 of the said regulations shall apply to the International Financial Services Centre Unit specified against serial number 7 under column (2) of the said table;
