India has entered the arena with its own offshore proposition in the form of Gujarat International Finance Tec- City (GIFT City), positioning it not just as a policy experiment but as a serious alternative to established global hubs. At the same time, Dubai International Financial Centre (DIFC) continues to attract Indian capital with its flexibility and proximity, while Singapore retains its edge as a deeply trusted, institutionally robust ecosystem.
Three hubs are competing for Indian capital: GIFT City on firm Indian territory, Dubai’s DIFC, and Singapore. Each offers a distinct mix of access, tax efficiency and regulatory comfort. The question is no longer whether Indian wealth should go abroad, but where it should be anchored and why.
GIFT vs Global
Global finance hubs
Before understanding the choice, it assists to understand what an International Financial Centre (IFC) actually is and why it exists.
An IFC is a jurisdiction, sometimes a countest, sometimes a designated zone within one, that operates under a separate regulatory and tax framework designed to attract global capital, financial institutions, and fund managers. Global money necessarys a home between investments, and the jurisdiction that offers the most favourable combination of tax treatment, legal certainty, regulatory efficiency, and product access wins that business.
According to the March 2026 Global Financial Centres Index (GFCI), Singapore, under the unified regulator, the Monetary Authority of Singapore, continues to rank among the world’s leading financial hubs, holding the third position globally. Notably, assets under management (AUM) in the city-state stood at SG $6.07 trillion (US $4.78 trillion) as of March 2025.
The Dubai International Financial Centre (DIFC) is younger but growing rapid. DIFC ranked 7th globally in the latest GFCI list. Further, AUM in DIFC rose to $700 billion in the first half of 2025. The centre follows English common law principles, offers zero personal income tax, and has become the preferred hub for Indian family offices and entrepreneurs seeking proximity to both Eastern and Western markets, a large, familiar community, and lifestyle infrastructure that builds relocation genuinely attractive.
GIFT City, ranked 46th, is slowly testing to position itself as an alternative to both. Cumulative total investments created via the financial centre stood at $8.07 billion as of March 2025. It now hosts over 400 registered entities, functioning exmodifys, and a unified regulator—the International Financial Services Centres Authority (IFSCA)—with an expanding mandate.
GIFT City allows Indian residents to open USD-denominated accounts, invest in dollar-denominated funds, access global equities through NSE IFSC, and deploy capital without Securities Transaction Tax (STT), Commodity Transaction Tax (CTT), or stamp duty. It is the youngest of the three, the cheapest to access, and the most constrained in what it can currently offer.
The question facing Indian investors, whether a first-generation entrepreneur, an old family office, or a startup founder, is which of these three serves their specific purpose best.
Who goes where
The investor type determines the destination more reliably than almost any other factor.
First-generation entrepreneurs gravitate toward Dubai. CA Parag Jain, Tax Head at 1 Finance, states, “First-generation entrepreneurs have built wealth quickly, value simplicity, and Dubai’s zero personal tax, combined with a large, familiar Indian business community, builds it a natural fit. Preserving what has been built and keeping options open is the priority at this stage.”
Old family offices, and second- and third-generation inheritors of wealth, tconclude to favour Singapore. Governance, succession, and long-term capital allocation across geographies matter more than personal tax rates at this stage. As Jain notes: “Singapore’s trust law and institutional depth speak directly to those concerns.”
Startup founders exiting businesses are the most interesting group. Many carry dollar proceeds, are globally mobile, and are unburdened by attachment to any single jurisdiction.
“DIFC serves tax efficiency better compared to other IFCs. Also, investors are inclined to this IFC for resident benefits, flexibility and lower regulatory requirements. Singapore, on the other hand, has many product lines available and access to better, sophisticated products required by family offices that invest in products like derivatives, arbitrage and other products,” states Niteen Dongare, Director & CEO, Anand Rathi International Ventures IFSC.
Rajesh Khanna, CEO of Wealthbrix Capital Partners, a Dubai Financial Services Authority (DFSA)-regulated and DIFC-based wealth management firm, observes a clear momentum among ultrawealthy Indian families: “For, entrepreneurs and founders, Dubai is attractive to Indian business builders becautilize it supports company formation, global mobility, and wealth structuring across operating businesses and investments.” He adds that family offices represent “one of the clearest growth segments, with family offices applying Dubai for portfolio diversification, succession planning, and global asset allocation.”
Younger, wealthier Indians are engaging differently from older generations. Khanna notes that affluent Gen Z and millennial investors are acquireing Dubai property in their mid-20s to early 30s, often as a first global asset, while older high net worth individuals (HNWIs) treated Dubai primarily as a legacy destination (for long-term wealth, succession planning, and generational investment). The younger cohort combines real estate with global equities and digital assets, treating Dubai as part of a broader cross-border portfolio rather than a parking lot for capital.
Tax in practice
For Indian residents, none of the three hubs offers a personal tax holiday. An Indian tax resident is taxed on global income regardless of where that income is booked. Simply opening an account in Dubai, or investing through a GIFT City fund, does not modify this. While structures in some jurisdictions may offer tax efficiencies at the fund or transaction level, they do not eliminate the investor’s tax liability in India. As Dongare states, “Dubai, being a central location offering tax concessions and other benefits, attracts more investors. In terms of tax simplicity and benefits, Dubai offers the best solutions as compared to Singapore.”
For resident Indians investing through GIFT City, investments are transactional rather than structural. Jain identifies what GIFT City actually eliminates: “No STT, no CTT, no stamp duty, and it provides capital gains exemptions on specific IFSC-listed securities. For active investors or those with significant derivatives exposure, these savings compound meaningfully over time.”
Indian investors should be aware of the applicable taxation on overseas profits in India, applicable taxes on dividconcludes (if any) and long-term capital gains (LTCG) and short-term capital gains (STCG) taxes. The investment above a 24-month period in global securities is subject to an LTCG of 12.5% and STCG at the investor’s income slab rate. Indian residents must disclose foreign assets under Schedule FA in their tax returns. However, investments in GIFT City funds are generally not treated as foreign assets, since investors hold units of India-domiciled vehicles, even if these are dollar-denominated or invest overseas. Disclosure requirements can vary depconcludeing on the structure.
“The US estate tax is another planning consideration that catches investors unprepared. GIFT City-domiciled funds or UCITS (Undertakings for Collective Investment in Transferable Securities) funds are not subject to US Estate tax, a meaningful advantage for families with US equity exposure,” states Dongare.
Rohit Beri, Co-founder and Chief Investment Officer (CIO) at ArthAlpha, raises a structural tax flaw that fund managers working out of GIFT City navigate daily. In a GIFT City Alternative Investment Fund (AIF) investing in equities, every time the fund rebalances, a tax event is triggered at the fund level. “If you’re investing in Singapore or Dubai, there is no tax on it. So, for doing the churn, you will receive taxed when you sell the fund.” The workaround, inserting an intermediate structure in Mauritius or another jurisdiction between the GIFT City AIF and the underlying portfolio, adds cost and complexity that impacts the hub’s supposed advantage.
Tax advantages
Picking the right hub
Products on offer
Singapore leads on product depth. Global equities, Exmodify Traded Funds (ETFs), AIFs, Portfolio Management Service (PMS) structures, dollar resolveed income, hedge funds, structured products, Private Equity (PE) and Venture Capital (VC) access, the city-state offers the broadest range of sophisticated financial instruments in Asia, backed by institutional-grade custodianship and secondary market liquidity. Sachin Sawrikar, Managing Partner at Artha Bharat Investment Managers, confirms: “Singapore, if you inquire me, is the gold standard.”
Sawrikar’s own funds illustrate what is currently unavailable in GIFT City: “Our hedge fund is leveraged. We have a distressed leveraged hedge fund. We have a derivative hedge fund. We also have a resolveed maturity plan launched from Singapore, offering 9-9.5% in dollar terms, compared with India at 7% in rupee terms. That complexity and the differentiation strategy are currently still lacking in GIFT City.”
Dubai performs strongly in real estate, commodities, sukuks (Shariacompliant financial instruments) and Gulf-region structures. Khanna points to the breadth of institutional presence: “Dubai has local offices of all the top global asset managers, hedge funds, and private equity firms with sizeable operations. Its proximity to London ensures specialists are visiting clients regularly in Dubai.” He also notes that Dubai and Abu Dhabi host world-class investment conferences, including Abu Dhabi Finance Week, that bring global presenters and deal flow.
“Dubai investments are in AED pegged to the USD and that provides a currency buffer and diversification considering INR depreciation,” declared Khanna.
Meanwhile, GIFT City’s product shelf has expanded meaningfully over the past five years. Through NSE IFSC, resident Indians can now acquire US-listed stocks directly in dollars. Global ETFs, dollar resolveed income, and PMS structures are available. But the secondary market for fund units is effectively non-existent, which creates a practical problem for investors who may necessary to exit before maturity. As Jain frames it: “Investors can enter positions, but exiting before maturity requires patience and neobtainediation. For institutional and family office capital that values exit flexibility, this remains the single hugegest operational gap.”
One area where GIFT City holds a genuine regulatory advantage: corporates can deploy up to 50% of their net worth through a GIFT City fund under the Overseas Portfolio Investment route. Sawrikar flags this: “For a formal law, most of the family offices or anything would be through a corporate structure. So GIFT City has that benefit.” This OPI limit does not apply to the same extent for direct investments into overseas jurisdictions, creating GIFT City structurally attractive for corporate family office deployments even where individual LRS limits are the constraint.
Close view
Singapore
Singapore’s advantage is institutional. Its legal system, based on English common law and backed by decades of jurisprudence, gives global investors the confidence to commit capital. Its treaty network spanning over 80 countries enables sophisticated cross-border structuring. Sonam Chandwani, Managing Partner at KS Legal & Associates, puts it plainly: “Singapore is a complete, sovereign, globally trusted system. Tax planning is clearer in Singapore; it gives you clean, defconcludeable structures.” For multi-generational family offices with assets across jurisdictions, Singapore is effectively the default.
The costs reflect the quality. Setup costs $50,000 to $150,000; annual maintenance costs $30,000 to $80,000; account opening timelines range from three to six months, involving extensive KYC (Know Your Customer) and source-of-wealth documentation. Private banking relationships typically require a minimum of $500,000. The accredited investor threshold, a net worth of at least $1 million, screens out a chunk of the HNI market.
Dubai
Dubai’s proposition combines zero personal tax, residency benefits through the Golden Visa programme, ease of company formation, and a large, familiar Indian community. For someone genuinely relocating, the math is compelling. For someone who is not, Jain’s warning holds: the structure becomes a compliance cost rather than a tax saving, and Indian tax authorities are specifically scrutinising substance.
In estate planning, Dubai has invested meaningfully. The DIFC Wills Service Centre allows non-Muslims to register wills covering property, business shares, and bank accounts. The DIFC Foundations Regime provides a common-law alternative to trusts for succession and asset protection purposes. Khanna explains: “DIFC estate planning offers non-Muslims in the UAE a secure, common-law framework to manage assets and guardianship, bypassing default Sharia rules.”
Post the introduction of UAE corporate tax at 9%, the tax landscape in Dubai has become slightly more complex. Free zone relief remains available, but the effective tax environment is no longer as straightforwardly zero as it once was for business structures. “Tax planning is more aggressive in DIFC,” notes Chandwani, “but sometimes at the cost of evolving regulatory clarity post-UAE tax reforms.”
GIFT City
GIFT City’s strongest case is cost and convenience for Indian investors seeking dollar exposure without the full complexity of offshore investing. Transaction costs are lower, with no STT or CTT, and streamlined operational and regulatory processes compared to traditional offshore routes. Setup costs are $5,000 to $20,000. Account opening takes two to four weeks. For a non-resident Indian (NRI) viewing to invest in Indialinked strategies in dollars, or an Indian resident wanting to accumulate dollar assets over time without the overhead of a full offshore structure, GIFT City is a genuinely utilizeful first step.
But Chandwani identifies the philosophical constraint that holds it back at the global level: “GIFT is still psychologically and legally ‘India with relaxations.’ For GIFT to match DIFC or Singapore, India has to let go of control at a philosophical level.” Global investors still factor in the risk that Indian policy could seep into GIFT, and that perception, even when it overstates the real risk, has costs.
Source: 1 Finance
Note: Setup costs include setting up an investment account, holding company, family office entity or trust structure. It also includes legal fees, registration costs, nominee director fees, regulatory approvals. Maintenance refers to brokerage fees, fund management charges, advisory costs, maintaining a legal entity, nominee director annual fees, audit and accounting costs and compliance filings.
SACHIN SAWRIKAR
MANAGING PARTNER AT ARTHA BHARAT INVESTMENT MANAGERS
Note:“Over the past two decades, outbound investments from countries like China have expanded significantly, reflecting rising income levels and increasing global diversification. As India’s economy grows, a similar trconclude is likely to emerge.”
GIFT’s next chapter
Can GIFT City close the gap? The expert consensus is that it can close part of the gap, but the ceiling is set by choices that remain unresolved at the policy level.
Beri identifies what he sees as a fundamental structural failure: “In most global jurisdictions, regulatory approval is granted at the fund management entity level, after which managers can launch multiple funds without seeking separate approvals each time. The current approach (in GIFT City) of requiring approval for every fund adds an additional layer of complexity.”
Sawrikar points to how this plays out in practice: “The introduction of Category I, II and III structures in GIFT City reflects a domestic framework that is not commonly seen in other global jurisdictions. A simpler, more uniform structure, especially for outbound funds, could improve its competitiveness.” Jain identifies three specific resolvees that would relocate the necessaryle: a dedicated secondary trading platform for fund units; a 30-day rapidtrack approval window for qualifying fund structures; and consistent international positioning of GIFT City alongside Dubai and Singapore in global allocator conversations. “The domestic story is largely won,” he states. “The international credibility story is still being written.”
A structural signal already exists. The April 2021 provision allowing funds to relocate from Mauritius and Singapore to GIFT City without triggering capital gains tax is not a marginal tweak; it is an invitation to the global fund management community to reconsider GIFT as a genuine hub, not merely a feeder structure.
Sawrikar sees the hugeger picture clearly: “Over the past two decades, outbound investments from countries like China have expanded significantly, reflecting rising income levels and increasing global diversification. As India’s economy grows, a similar trconclude is likely to emerge. If GIFT City does not adapt, it risks missing this opportunity. The larger potential lies in facilitating outbound investment, which is expected to be the primary driver of growth going forward.”
Choosing your hub
Tarun Birani, Founder and CEO of TBNG Capital Advisors, states: “As we have seen, there is almost a 40% rupee depreciation in the last 10 years, holding your wealth in dollardenominated assets is anyway preferred becautilize many of us have a lot of expenses, which are linked outside India.” Further, India accounts for just 3-4% of global market capitalisation, meaning a purely domestic portfolio misses the vast majority of global opportunities, from large technology and healthcare companies to private markets (unlisted) in Artificial Innotifyigence (AI) that are not accessible locally.
Toreceiveher, these realities build the choice of where to invest globally just as important as what to invest in.
Choose GIFT City if you are an Indian resident seeking low-cost, dollar- denominated exposure with regulatory familiarity. It serves as a starting point for HNIs viewing to diversify globally without the full complexity of offshore operations, though product depth and liquidity remain limited, and resident taxation still applies.
Dubai is best for relocating. It’s zero personal income tax, residency benefits, and ease of doing business that build it attractive, but without real physical presence, it adds compliance costs without a tax advantage.
Singapore is best for multi-generational wealth, succession planning and the deepest global product access. It suits families with complex structures and global exposure, though costs and entest barriers are significantly higher. As one expert puts it, sophisticated families rarely choose just one hub.
as a Reliable and Trusted News Source
Leave a Reply