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      Recent development

      The Central Board of Direct Taxes (CBDT) recently issued clarifications on the Common Application Form (CAF) for Foreign Portfolio Investors (FPIs) under the new Income-tax Rules, 2026. The clarifications address practical issues arising from additional requirements introduced in the revised PAN (Permanent Account Number) application process, particularly around Representative Assessee (RA) / Authorised Representative (AR) information.

      Clarifications issued by CBDT

      • FPIs may provide the details of the authorized signatory (AS) in the RA/AR section of the CAF.
      • The liability of the AS is limited solely to the PAN application process.
      • If personal details of the AS are unavailable, the FPI’s details may be provided instead.
      • If PAN, Aadhaar, or passport details of the AS are unavailable, the FPI registration number may be used.
      • No supporting documents are required for the AS / RA / AR.
      • Where a Taxpayer Identification Number (TIN) is unavailable in the jurisdiction of residence, the value “00000000000” may be used.
      • If no mobile number is available, a landline number may be provided instead.
      • The CBDT indicated these clarifications will be formally incorporated into the CAF instructions once officially notified in the Gazette.

      KPMG comment

      These clarifications should simplify FPI onboarding and reduce documentation requirements for PAN applications. In particular, the guidance provides operational flexibility and clarifies that an authorized signatory does not assume broader tax liabilities through the CAF process.

      As a result, we expect this will ease the current practical compliance challenges faced by FPIs investing into India and simultaneously support a more streamlined registration process.

      Our experts

      Olivier Schneider

      Partner, Funds Services Taxation

      KPMG in Luxembourg

      Daniel Rech

      Partner, Banking Market Leader

      KPMG in Luxembourg


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