The Central Government has notified the Social Protection Fund (SPF), Oman, as a specified person for the purpose of availing tax exemption in respect of eligible investments made in India under the provisions of the Income-tax Act, 2025.
The notification has been issued by the Ministry of Finance, Department of Revenue, through the Central Board of Direct Taxes vide Notification No. 84/2026, dated 15 July 2026. The corresponding Gazette notification has been published as S.O. 3890(E).
The Social Protection Fund, bearing Permanent Account Number ABOCS3010J, has been specified under Schedule V, Table Sl. No. 7, Note 5(a)(iii)(D), read with Section 11 of the Income-tax Act, 2025.
The tax exemption will apply to eligible investments made by the Fund in India on or after the date of publication of the notification in the Official Gazette and on or before 31 March 2030, subject to fulfilment of the conditions prescribed in the notification.
The Fund will be required to file its income-tax returns for all relevant previous years, beginning from the year in which an eligible investment is made and continuing until the year in which the investment is liquidated. Such returns must be filed within the prescribed due date under Section 263(1)(c) of the Income-tax Act, 2025.
Along with the income-tax return, the Fund will also have to furnish a compliance certificate from an accountant in Form No. 176, in accordance with Rule 282 of the Income Tax Rules, 2026.
The Social Protection Fund will be required to report details of every investment made by it in India during a quarter. The information must be furnished in Form No. 175 within one month from the end of the relevant quarter.
The Fund must maintain separate or segmented accounts of income and expenditure relating to investments that qualify for exemption under Schedule V of the Income-tax Act, 2025.
As a condition for continuing eligibility, the Social Protection Fund must remain regulated under the laws of the Government of Oman.
The Fund must continue to be responsible for administering or investing assets for meeting statutory obligations and defined contributions under funds or schemes established for providing retirement, social security, employment, disability, death benefits or similar compensation to their participants or beneficiaries.
The notification stipulates that the income and assets of the Fund must be used exclusively for meeting its statutory obligations and defined contributions for the beneficiaries of such funds or schemes. No part of its income or assets may be used for the benefit of any private person, except for permitted payments to creditors or depositors in respect of loans or borrowings taken for purposes other than making investments in India.
The Social Protection Fund must not have any direct or indirect loans or borrowings for the purpose of making investments in India.
The Fund will also not be permitted to participate in the day-to-day operations of an entity in which it invests. However, monitoring arrangements intended to protect the investment, including the right to appoint directors or an executive director, will not be treated as participation in the day-to-day management of the investee entity.
Any violation of the conditions prescribed under Schedule V of the Income-tax Act, 2025, or under Notification No. 84/2026, will render the Social Protection Fund ineligible for the tax exemption.
The notification comes into force from the date of its publication in the Official Gazette.
The Notification can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/07/CBDT-Notification-84-2026.pdf
