Income Tax: CBDT Extends Tax Exemptions for Global Pension Funds and Sovereign Wealth Funds

The Central Board of Direct Taxes (CBDT) has recently issued multiple notices dated July 11, 2025, informing that the Government of India has introduced some amendments to the previous notifications of the Government of India in the Ministry of Finance, Department of Revenue, in exercise of its powered granted under sub-clause (vi) and (iv) of clause (b) and (c) of Explanation 1 to clause (23FE) of section 10 of the Income-tax Act, 1961 (43 of 1961). These amendments uniformly extend the initial exemption due date from March 31, 2025, to March 31, 2030, granting a five-year extension for continued tax benefits on eligible investments.

Notification No. 74/2025 revises Notification No. 89/2020 to continue the exemption for MIC Redwood 1 RSC Limited in Abu Dhabi. Notification No. 75/2025 revises Notification No. 33/2021 to keep offering benefits to Norfund, which is the sovereign wealth fund of Norway’s government. In a similar way, Notification No. 76/2025 revises Notification No. 34/2021 to continue benefits for the Canada Pension Plan Investment Board.

Notification No. 93/2025 extends the exemption for the School Employees Retirement System of Ohio, as mentioned in Notification No. 130/2021. Notification No. 94/2025 revises Notification No. 84/2021 for 2726247 Ontario Inc. Notification No. 97/2025 revises Notification No. 111/2021 for 2452991 Ontario Limited.

These extensions indicate that the Indian government is committed to encouraging long-term foreign investment by offering a stable tax system for eligible global investors in infrastructure and related sectors.

CBDT Notification No. 74/2025 dated July 11, 2025:

The Central Government has amended Notification No. 89/2020 to extend the tax exemption period for the sovereign wealth fund, MIC Redwood 1 RSC Limited, Abu Dhabi, UAE, in exercise of its powers granted under the Income-tax Act, 1961. This amendment is revising the initial deadline from March 31, 2025, to March 31, 2030. This has granted five years of extension. This fund is recognised as a “specified person” under a specific rule (clause 23FE of Section 10) for qualifying investments made in India.

CBDT Notification No. 75/2025 dated July 11, 2025:

The Central Government has amended Notification No. 33/2021 to extend the tax exemption period under section 10(23FE) of the Income-tax Act, 1961, for the sovereign wealth fund, Norfund, Government of Norway. This amendment is revising the initial deadline from March 31, 2025, to March 31, 2030. This has granted five years of extension, made effective from April 1, 2025, till the date of publication of this notification. This fund is recognised as a “specified person” for qualifying investments made in India.

CBDT Notification No. 76/2025 dated July 11, 2025:

The Central Government has amended Notification No. 34/2021 to extend the tax exemption period under section 10(23FE) of the Income-tax Act, 1961 for the Canada Pension Plan Investment Board. This amendment is revising the initial deadline from March 31, 2025, to March 31, 2030. This extension has been made effective from April 1, 2025, till the date of publication of this notification, offering continued tax benefits for the Indian investments of the pension fund.

CBDT Notification No. 93/2025 dated July 11, 2025:

The Central Government has amended Notification No. 130/2021 to extend the validity period for the specified pension fund, the School Employees Retirement System of Ohio, in exercise of its powers granted under the Income-tax Act, 1961. This amendment is revising the initial deadline from March 31, 2025, to March 31, 2030, permitting the fund to continue utilising exemption benefits on its qualifying investments until the new revised date. This fund is recognised as a “specified person” under a specific rule (clause 23FE) for qualifying investments made in India.

CBDT Notification No. 94/2025 dated July 11, 2025:

The Central Government has amended Notification No. 84/2021 under the Income-tax Act, 1961, to extend the tax exemption eligibility for the pension fund 2726247 Ontario Inc. This amendment is revising the initial deadline from March 31, 2025, to March 31, 2030, permitting the fund to continue utilising exemption benefits on its qualifying investments until the new revised date. This fund is recognised as a “specified person” under a specific rule (clause 23FE) for qualifying investments made in India.

CBDT Notification No. 97/2025 dated July 11, 2025:

The Central Government has amended Notification No. 111/2021 under the Income-tax Act, 1961, to extend the tax exemption period for the pension fund 2452991 Ontario Limited. This amendment is revising the initial deadline from March 31, 2025, to March 31, 2030, permitting the fund to continue receiving tax benefits on qualifying investments in India until the new revised date. This fund is recognised as a “specified person” under a specific rule (clause 23FE) for qualifying investments made in India.

Refer to the official notifications for complete information.