Fund Formation & Structuring

While deciding on the optimum structure for a fund, varied objectives like limited liability for investors, tax efficiency for the investors and the managers need to be considered. Further, offshore funds investing in India would require the presence of investment advisors in India to provide them with deal recommendations etc. This gives rise to tricky issues relating to the taxation of the offshore fund in India that would depend on whether the Indian advisor is regarded as a "permanent establishment" of the offshore fund in India.