§01 · EDITORIAL · GLOSSARY · AIF

AIF — Alternative Investment Fund

Glossaryglossary

Definition

An Alternative Investment Fund (AIF) is any privately pooled investment vehicle that collects funds from sophisticated investors for investing per a defined investment policy, regulated by SEBI (Alternative Investment Funds) Regulations, 2012. Three categories: Category I (venture capital, infrastructure, social impact, SME funds — eligible for regulatory/GoI incentives); Category II (private equity, debt, real estate funds); Category III (hedge funds using complex/leveraged strategies). Minimum investment ticket: ₹1 crore per investor (₹25 lakh for directors/employees of the AIF/manager). Minimum corpus per scheme: ₹20 crore. AIFs cannot make a public offer.

How it works

AIFs raise capital via private placement from accredited/HNI investors, deploying per a SEBI-filed placement memorandum. Category I/II AIFs are closed-ended with minimum 3-year tenure; Category III may be open or closed. Cat III AIFs may leverage up to 2x NAV. Cat I/II AIFs are pass-through for tax; Cat III AIFs are taxed at fund level. NRI investments on repatriation basis are governed by FEMA 20(R) Schedule 4; downstream AIF investment in Indian companies with NRI capital triggers Form FC-GPR FEMA reporting obligations.

Tax treatment

Category I and II AIFs: pass-through — income/losses retain their character and are taxed in investors' hands. Category III AIFs: taxed at fund level at maximum marginal rate applicable to income type (surcharge included). Budget 2023 clarified Cat III AIFs holding listed securities are subject to STT-based LTCG (12.5%)/STCG (20%) at the same rates as direct equity. For NRI investors in pass-through AIFs, income retains its character and TDS is applied before remittance.

Worked example

Sameer, an NRI with ₹2 crore investible surplus, commits ₹1 crore to a Cat II PE-debt AIF targeting 14% IRR. Pre-tax gain over 5 years: ≈₹93.6 lakh. Assuming 60% return as interest income (taxed at 31.2% = ₹17.5 lakh) and 40% as LTCG (12.5% = ₹4.7 lakh): total tax ≈₹22.2 lakh. Net post-tax IRR: ~11.2%. AIF's higher return reflects illiquidity premium and credit risk — structurally differentiated from EPF (8.25%) or PPF (7.1%) EEE instruments.

Primary source

SEBI AIF Regulations 2012 — sebi.gov.in

Disclosure: MintByte Investment Advisers is a SEBI-Registered Investment Adviser (RIA) bearing registration number INA000017633 and SEBI Research Analyst registration number INH000014245, ARN-314872, and APMI APRN-01658. The information contained herein is for educational and informational purposes only and does not constitute investment advice or a solicitation to buy or sell any securities or investment products. Past performance is not indicative of future results. Investors are advised to read all scheme-related documents carefully and consult a qualified financial adviser before investing.

Reviewed · January 2026