GIFT City vs Singapore vs Mauritius: A Structuring Comparison for Fund Sponsors

For years, the default domicile conversation for a fund with India exposure had two real answers: Mauritius, for its treaty history and familiarity, or Singapore, for its institutional credibility and broader regional platform. GIFT City is now a genuine third option - not a replacement for either, but a materially different trade-off that deserves to be evaluated on its own terms rather than dismissed as "still developing." The comparison below is our analytical view based on the publicly available regulatory and tax framework for each jurisdiction, not a market survey - treat it as a starting framework for your own evaluation rather than a definitive ranking.

The tax comparison

GIFT City's core offer is a 100% income-tax deduction for 10 consecutive years out of a 15-year block under Section 80LA - a genuine holiday rather than a rate concession - plus GST, stamp duty and STT/CTT exemptions on IFSC transactions, and a reduced 9% MAT rate. Mauritius's traditional appeal rested heavily on treaty-based capital-gains relief, which has been narrowed by successive amendments to the India-Mauritius tax treaty over the years (most significantly the 2016 protocol phasing out the old capital-gains exemption for share investments). Singapore offers a stable, internationally credible tax and legal environment with its own treaty network, but does not offer an India-specific tax holiday of GIFT City's scale for funds actually structured to invest into or via India.

In our view, GIFT City competes hardest against Mauritius on India-focused structures, since Mauritius's treaty advantages have narrowed over the same period GIFT City's incentive package has strengthened. Against Singapore, the comparison is less about tax rate and more about what comes next - a client should get current, mandate-specific tax advice on all three jurisdictions rather than relying on this general framing alone.

The regulatory-maturity comparison

This is where Singapore still has a real edge, and it would be dishonest to pretend otherwise. Singapore's regulatory and judicial infrastructure has decades of fund-industry precedent behind it - established case law, deep bench of specialist advisors, and a fund-servicing ecosystem that has scaled over a long period. GIFT City's core fund-management framework has been repealed and replaced once (2022 Regulations to 2025 Regulations) and amended multiple times since, most recently via circulars issued as recently as April 2026. That pace of change is a sign of a regulator actively refining a young framework - a reasonable and arguably healthy thing for a developing jurisdiction to do - but it is a genuinely different risk profile from Singapore's comparative stability.

Mauritius sits in between: a long-established offshore fund domicile with real institutional infrastructure, but one whose commercial rationale for India-focused structures has weakened as treaty benefits have narrowed.

The substance and proximity comparison

GIFT City's strongest structural argument is proximity - both physical and regulatory. A fund manager running an India-focused or India-adjacent strategy can operate from GIFT City with a safe harbour (Section 9A) against inadvertently creating a taxable business connection in India, while being materially closer to the deal flow, the portfolio companies, and the on-the-ground due-diligence relationships that an India strategy actually depends on. Neither Mauritius nor Singapore offers that same proximity, by definition.

Where each one genuinely wins

Choose GIFT City if the fund's mandate is meaningfully India-focused, the sponsor is comfortable with a still-maturing regulatory environment in exchange for a stronger incentive package and physical proximity, and the fund's target corpus fits comfortably within GIFT City's now-lowered minimum thresholds.

Choose Singapore if the fund's mandate is regional or global rather than India-specific, the investor base places a premium on jurisdictional maturity and precedent, or the strategy requires servicing infrastructure that GIFT City's newer ecosystem has not yet fully built out.

Choose Mauritius primarily where an existing structure already benefits from grandfathered treaty positions, or where specific legacy considerations make migration more costly than the incremental benefit of moving elsewhere.

The takeaway

This is not a contest with one winner - it is three genuinely different trade-offs, and the right answer depends on the fund's actual mandate more than on which jurisdiction currently has the most favourable headline numbers. A sponsor evaluating this decision should be wary of any advisor presenting it as an obvious choice in either direction.