PMS, AIFs and NPS compared with mutual funds
Three Indian products that sit beside mutual funds but follow other rules. We show who may join from abroad, what India taxes and what is still not settled abroad. We recommend nothing.
Prepared by Prem Tax and Accounting Corp. Last checked against official sources on November 5, 2026.
Portfolio management services (PMS), alternative investment funds (AIFs) and the National Pension System (NPS) are not mutual funds. Our Three-Pocket Paper Trail keeps the papers in order.
- PMS: securities held in your own name. Rs 50 lakh minimum, with exceptions. New rules start 1 April 2027.
- AIF: a private fund, Rs 1 crore minimum. Since October 2026 SEBI deems people living abroad accredited investors, which waives it.
- NPS: a pension account. NRIs and OCIs: Tier I only; FEMA lets the money go abroad.
Side by side
| Item | PMS | AIF | NPS | Mutual fund |
|---|---|---|---|---|
| Regulator | SEBI | SEBI | PFRDA | SEBI |
| Minimum | Rs 50 lakh; none if accredited | Rs 1 crore; none if accredited | A small yearly minimum | The fund house sets it |
| From abroad | Yes, like listed shares (our reading) | Persons abroad, except citizens and entities of Pakistan and Bangladesh; SEBI also tests the home regulator | NRIs and OCIs | NRIs and OCIs; some houses refuse U.S. and Canada residents |
How India taxes it (FY 2026-27)
FY 2026-27 is tax year 2026-27 in the Income-tax Act, 2025 (1 April 2026 to 31 March 2027). Add 4% cess. Rates change yearly.
| Product | How India taxes it |
|---|---|
| PMS | No PMS-level tax. Our reading: capital gains on shares sold on the exchange. Held over 12 months, 12.5% on gains above Rs 1.25 lakh a year; sooner, 20%. Business income is possible |
| AIF, Category I and II | Passed through, as if you invested directly; business income is taxed in the fund |
| AIF, Category III | Taxed in the fund under trustee rules; what investors then pay is not settled |
| NPS | Up to 60% of the amount paid on closure is exempt. The rest of an 80% lump sum may be taxable: not settled |
Abroad: USA, Canada and the UK
| Country | What is known | Not settled |
|---|---|---|
| USA | PMS shares are tested one by one as possible PFICs. The IRS lists foreign hedge and private equity funds on Form 8938, not the FBAR | AIF: corporation, partnership or trust? NPS: FBAR, Form 8938, trust status |
| Canada | Shares, fund units and trust interests count for Form T1135 above CAD 100,000 of cost (tax years 2025 and 2026) | AIFs under sections 94 and 94.1; NPS as an exempt pension trust |
| UK | HMRC's reporting-fund list names some Indian AIF classes | PMS and NPS: no HMRC text found |
Our checklist
The Three-Pocket Paper Trail: one folder per product.
- PMS: the agreement, demat statement and trade records.
- AIF: the placement document, accreditation reply and unit statement.
- NPS: the PRAN (permanent retirement account number) statement and contribution dates.
- Every pocket: the NRE, NRO or FCNR account used, and written replies on foreign reporting.
Common questions
Can an NRI join a PMS with less than Rs 50 lakh?
Accredited investors are exempt. SEBI's circular of 5 November 2026 deems people living abroad accredited and refers to the PMS rules that start 1 April 2027. The current rules still ask for a certificate, so the position until then is not settled.
Is the whole NPS lump sum tax-free?
Not on the current text. Invented example: from a Rs 50,00,000 corpus, a Rs 40,00,000 lump sum has Rs 30,00,000 exempt (60% of the corpus). The other Rs 10,00,000 may be taxable. Not settled.
Does the IRS exempt NPS from reporting?
Not that we found. Rev. Proc. 2020-17 covers only Forms 3520 and 3520-A and lists no countries; NPS appears not to meet its tests (our reading). See our [Indian CPA page](/indian-cpa/).
Official sources
- SEBI: Portfolio Managers Regulations, 2026 (in effect from 1 April 2027)
- SEBI: Alternative Investment Funds Regulations, 2012 (to 15 October 2026)
- PFRDA: Circular on NRI and OCI subscribers, 2 December 2025
- PFRDA: Key changes to the NPS exit regulations
- RBI: Master Direction, Foreign Investment in India
- Income-tax Act, 2025 (Gazette of India)
- SEBI: Circular of 5 November 2026, Review of the framework for Accredited Investors
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