For two decades, the default fund-domicile question for managers operating between India and the world had a short answer: Cayman or Singapore for the master, with a Mauritius or Singapore feeder for tax-treaty efficiency. That answer is no longer always right. The IFSCA-regulated framework at GIFT City has matured to the point where, for a meaningful share of India-focused or India-outbound mandates, GIFT now wins on cost, governance, and counterparty signalling.

The case for GIFT runs through three points. First, the regulatory regime is genuinely first-class — IFSCA was modeled on Singapore's MAS and the DFSA, and the AIF Cat I / Cat II / Cat III categories cover the standard private-credit, private-equity, and venture mandates with clear, predictable rules. Second, the tax treatment is competitive — no GST on management fees, no capital-gains tax for non-resident investors on most exit profiles, and an explicit ten-year corporate-tax holiday subject to specific conditions. Third, the LP perception has caught up — Indian family offices, which now write the bulk of growth-round capital in the country, increasingly prefer GIFT-domiciled vehicles for both tax-treaty alignment and regulatory familiarity.

Where GIFT still does not work: global mandate funds raising materially from outside India (where Cayman remains friction-free for US LPs), highly-structured credit vehicles (where Cayman's SPV depth is unmatched), and managers who require US-style "check the box" tax elections that IFSCA does not currently mirror.

The decision tree we use with managers is straightforward: if the LP base is at least 60% Indian or India-tied, and if the underlying assets are India-domiciled or India-flowing, GIFT now beats Cayman on every dimension that actually matters to the fund's economics. If the LP base is dominantly US, EU, or Gulf with global mandates, the legacy choice still holds. The middle case — mixed LP base, cross-border deal flow — is where the conversation gets interesting, and where Brillwood's Capital practice is increasingly being asked to weigh in.