Contents
Definition
A Fund of Funds — Domestic (FoF Domestic) is a SEBI-regulated mutual fund category under the Categorisation and Rationalisation Circular (October 2017). Rather than investing directly in securities, a domestic FoF allocates its corpus to units of other domestic mutual fund schemes registered with SEBI. The structure creates a second layer of management — the FoF manager selects and monitors underlying schemes, while each underlying scheme has its own fund manager and investment mandate. Finance Act 2023 §50AA significantly altered the tax treatment of FoF structures, making the domestic tax framework critical to evaluate before comparing FoF returns with direct equity alternatives. Each AMC may operate one FoF Domestic scheme per investment objective, subject to distinct scheme documentation.
How the category is defined
SEBI's Categorisation Circular specifies:
- Minimum 95% of total assets invested in other mutual fund schemes registered with SEBI
- Underlying schemes must be domestic SEBI-registered schemes (not foreign funds or ETFs on foreign exchanges)
- AMC restriction: The FoF may invest in schemes of other AMCs; concentration in own-AMC schemes must be disclosed
Common FoF Domestic structures include: (a) multi-manager FoFs diversifying across multiple AMC schemes, (b) asset allocation FoFs rebalancing between equity, debt, and gold fund categories, and (c) ETF FoFs that invest in Nifty/Sensex ETFs listed on NSE/BSE. AMFI's bi-annual list tracks all registered FoF schemes by sub-type.
Tax treatment
Under Finance Act 2023 §50AA, all Fund of Funds — domestic and overseas — are treated as debt-oriented instruments for tax purposes, irrespective of the equity content of underlying schemes:
- Capital gains: Taxed at the investor's applicable income tax slab rate, regardless of holding period
- No LTCG benefit: Even if the underlying schemes are pure equity funds, the FoF wrapper causes gains to be taxed as ordinary income
- IDCW payouts: Also taxable at slab rate
This tax treatment is a material disadvantage vs investing directly in the underlying equity schemes. Investors should quantify the tax differential explicitly when evaluating a domestic equity FoF against its equivalent direct equity basket.
What investors should look at
Relevant factual parameters:
- Total expense ratio (TER) drag: The FoF charges its own TER on top of the TERs of underlying schemes. SEBI Regulation 52(6A)(b) caps FoF TER at 2.25% for equity-oriented underlying and 2% for others, but the combined drag reduces net returns materially. Compare the FoF's net return against direct investment in the same underlying schemes.
- Rebalancing cost efficiency: For asset allocation FoFs, each rebalancing trade happens at the fund level without triggering a tax event for unit-holders — this is the structural tax-efficiency counterpoint to the double TER.
- Underlying scheme quality: Review the track record, consistency quartile, and alpha of each underlying scheme.
- Portfolio overlap: A multi-manager FoF may inadvertently hold similar stocks across different underlying schemes; check scheme-level portfolio overlap.
Worked example
A hypothetical Multi-Manager FoF with ₹800 Cr AUM invests 30% in a large-cap direct fund (TER 0.8%), 30% in a mid-cap direct fund (TER 1.1%), 25% in a short-duration debt fund (TER 0.4%), and 15% in a gold ETF fund-of-fund (TER 0.3%). The FoF itself charges 0.5% TER. Weighted underlying TER ≈ 0.75%; combined effective drag ≈ 1.25%. A direct investor replicating these allocations by buying each fund independently would incur only the underlying TER (0.75%), saving 0.5% annually. However, the FoF manages rebalancing automatically without tax friction from switches — a trade-off that must be evaluated based on investor tax bracket and investment horizon.
See also
Primary source
SEBI Categorisation Circular, October 2017; Finance Act 2023 §50AA
MintByte (ARN-314872 / APMI APRN-01658) is a SEBI-registered investment adviser. This glossary entry is for educational purposes only and does not constitute investment advice. Mutual fund investments are subject to market risks. Please read all scheme-related documents carefully before investing.