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This research paper provides a comprehensive analysis of the factors influencing investments by Sovereign Wealth Funds (SWFs) and Pension Funds (PFs) in India, as well as their significant contribution to the country’s economic growth. With India’s robust growth potential, well-structured legal framework, and mature financial markets, the nation has emerged as a highly attractive destination for institutional investors. In recent years, SWFs and PFs have evolved from being passive limited partners in private equity funds to becoming direct investors in Indian enterprises. This shift has resulted in increased capital inflows into critical sectors such as infrastructure, healthcare, asset management, data centers, and renewable energy.
Furthermore, there is notable expansion of SWFs and PFs in the Gujarat International Finance Tec-City (GIFT City) in 2024, driven by targeted initiatives and strategic developments. This paper delves into the legal, tax, and regulatory considerations pertinent to SWFs and PFs investing in India. It specifically examines the tax exemptions available under Section 10(23FE) of the Income Tax Act, 1961, which allow SWFs and PFs to benefit from zero taxation on income derived from specified investments. As per the Finance Bill, 2025, These exemptions are proposed to be extended until March 31, 2030. Additionally, the paper explores various foreign investment avenues for SWFs and PFs, including Foreign Direct Investment, Foreign Portfolio Investment, and Foreign Venture Capital Investment, as well as investment vehicles such as Infrastructure Investment Trusts and Real Estate Investment Trusts.
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