Notification of Sovereign Wealth Fund under Schedule V of the Income-tax Act · Circular No. 03 of 2026

F.No.370142/46/2025-TPL Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes (TPL Division)

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Circular No. 03 of 2026 New Delhi, 30th March, 2026 Sub: Notification of Sovereign Wealth Fund under Schedule V [Table: SI. No. 7.Note S(a)(ii)(G)] of the Income-tax Act, 2025-reg.

Schedule V [Table: SI. No. 7] of the Income-tax Act, 2025 (hereinafter referred to as the Act) inter alia provides for exemption to income of a specified person in the nature of dividend, interest, any sum referred to in section 92(2)(k) of the Act or long-term capital gains (whether or not such capital gains are deemed as sho1t-term capital gains under section 76 of the Act) arising from investment made by it in lndia if the investment is made in specified infrastructure business (including business notified vide Notification F.No. 13/1 /2025-IPP dated 19.09.2025, i.e. Infrastructure sub-sectors mentioned in Harmonised Master List) during the period from O 1.04.2020 to 31.03.2030, and held for at least three years.

2. Specified person for this purpose inter alia includes notified sovereign wealth fund (SWF) which fulfils the conditions specified in Schedule [Table: SI. No. 7. Note 5(a)].

3. In order to facilitate the process of notification of the SWF, the Board, in exercise of powers conferred under section 239 of the Act, hereby specifies that the SWF shall file application in the Form I in the Annexure to this circular. The Form I shall be fi led with the Member, Central Board of Direct Taxes, Department of Revenue, Ministry of Finance, New Delhi having supervision and control over the work of Foreign Tax and Tax Research Division.

4. Fu1ther, the notified SWF shall be required to file return of income along with the audit report. It shall also be required to file a quarterly statement within one month from the end of the qua1ter electronically in Form II in respect of each investment made during the quarter in the Annexure to this circular.

5. The requirement of filing Form I and Form II by the SWF shall apply as follows:

5.1 Category I: SWF already notified under section 10(23FE) of the Income-tax Act, 1961

5.1.1 SWF which have already been notified under section 10(23FE) of the Income-tax Act, 196 1 are not required to file fresh application in Form I as provided in para 3. However, such notified funds shall be required to file a qua1terly statement within one month from the end of the quarter electronically in Form II as provided in para 4 in respect of each investment made during the qua,ter.

5.2 Category II: SWF seeking fresh notification under Schedule V [Table: SI. No. 7.Note S(a)(ii)(G)] of the Act

5.2.1 SWF seeking fresh notification under Schedule V [Table: SI. No. 7.Note 5(a)(ii)(G)] of the Act shall tile application in the Form I as provided in para 3 and such notified funds shall be required to file a qua1ierly statement within one month from the end of the quarter electronically in Form II as provided in para 4 in respect of each investment made during the qua1ier.

6. The Director General of Income-tax (Systems) shall lay down the data structure, standards and procedure for furnishing and verification of the Form I and Form I I and shall be responsible for formulating and implementing appropriate security, archival and retrieval policies in relation to the said forms so furnished.

7. This circular will be effective from 01.04.2026 and will apply for tax year 2026-27 and subsequent tax years.

Enclosure: Annexure

Copy to the:

1. PS/OSD to FM/ PS/OSD to MoS(F).
2. PS to the Finance Secretary.
3. PS to the Revenue Secretary.
4. Chairman and Members, CBDT. (Rohit Singh) Under Secretary (TPL-1) CBDT, New Delhi
5. Joint Secretaries/ CslT/Directors/Deputy Secretaries/Under Secretaries, CBDT.
6. C&AG of India (30 copies).
7. JS & Legal Advisor, Ministry of Law & Justice, New Delhi.
8. Institute of Cha1iered Accountants of India.
9. CIT (M&TP), Official Spokesperson of CBDT.
10. Principal DGIT (Systems) for uploading on the departmental website.

(Rohit Singh) Under Secretary (TPL-I) CBDT, New Delhi

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Annexure FORM I Application for notification under Schedule V [Table: SI. No.7.Note 5(a)(ii)(G)] (Sovereign Wealth Fund)

Part A: Particulars of the Sovereign Wealth Fund (SWF)

1. Name: (refer Note 1)
2. Address: (refer Note 2)
3. Communication Address in India: (refer Note 3)
4. Permanent Account Number (PAN):
5. Tax Identification Number (TIN): (refer Note 4)
6. Country ofresidence:
7. Set up under the law of (please mention the name of the foreign country)
8. E-mail Id:
9. Contact Number: Country Code, Number
10. Other details to be provided as separate enclosure: (attach as per Note 5)

Part B: Certification The applicant is a SWF and interested in making investment in terms of Schedule V [Table: SI. No. 7] and therefore, it is requested that necessary notification may kindly be issued. It is hereby certified that the SWF satisfies all the conditions mentioned in Schedule V [Table: SL No. 7 and SI. No.7.Note 5(a)(ii)]].

Verification I, , hereby affirm that the information provided in this application is true and correct to the best of my knowledge. I have not concealed any relevant fact. I am submitting this application in my capacity as ____ (designation), holding PAN and I am competent to verify and submit this application. Place: Signature: Date: Name: Designation:

Notes:

1. The name shall include full name of the Sovereign Wealth Fund.
2. The address shall include flc:!-tldoor/building, . road/street/block/sector, area/locality, post office, town/city/district, state, country/region and pin code/zip code.
3. The communication address in India shall include flat/door/building, road/street/block/sector, area/locality, post office, town/city/district, state and pin code.
4. TIN of the Sovereign Wealth Fund in the country or specified territory of its residence and in case no such number is available, then a unique number on the basis of which it is identified by the Government of that country or the specified territory of which it claims to be a resident.
5. With respect to Part A (SI. No. 10), following details shall be provided as annexures, namely: -

6. The application in this form is to be made to the Member (having supervision and control over the work of Foreign Tax and Tax Research Division), Central Board of Direct Taxes, Department of Revenue, Ministry of Finance, New Delhi.
7. The form is to be signed by the person competent to verify the return of income under section 265.
8. Some of the information in the form would be pre-filled to the extent possible.

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FORM II Intimation by Sovereign Wealth JFund of investment under Schedule V ('fable: SI. No. 7) (within one month from the end of the quarter ending on 30th June, 30th September, 31st December and 31st March of the financial year)

Part A: Particulars of the Sovereign Wealth JFund (SWF)

1. Name: (refer Note 1)
2. Address: (refer Note 2)
3. Permanent Account Number (PAN):
4. E-mail Id:
5. Contact Number: Country Code, Number

Part B: Other Details 6. Notification Number: 7. Notification Date: 8. Financial Year: 9. Quarter Ending: (refer Note 3)