Bottom Line

Indian HNI investments into offshore funds – RBI addresses industry concerns

2024-06-12

Author: Aditya Jain & Shivam Yadav

What?

  • Indian individuals can now invest in offshore investment funds setup as companies or partnerships, which though unregulated themselves are managed by a regulated investment manager as per the RBI circular dated June 07, 2024
  • Earlier, individuals could only invest in ‘units’ (of a trust) under the OPI route, disentitling Indian individuals to invest in offshore funds that are usually setup as companies or limited partnerships (trusts are seldom used as investment vehicles abroad)
  • Indian individuals are not permitted to invest in financial services under the ODI route; only OPI route permitted
  • Earlier, RBI master directions required the fund vehicle to be regulated – rather misaligned since in most jurisdictions, manager, and not the fund vehicle is registered / regulated

Bottom Line

  • Permitting OPI in funds beyond trusts provides the much-needed clarity since offshore funds are seldom setup as trusts
  • Offshore GPs likely to see enhanced interest from Indian HNIs – though overall limit continues to be capped at USD 250k per person per year
  • For investments beyond USD 250k, Indian investors could consider ODI route (up to 4x of net worth) through a company/ LLP; however investment must only be in ‘equity capital’ – investment in redeemable units of a trust may not be permitted
  • Similarly, regulated offshore GPs raising capital in unregulated funds should also get some respite