Alerts & Updates 18th Jun 2026

Variable Capital Company Fund Structures in the DIFC Singapore Mauritius and GIFT-IFSC – A Comparison

Authors

Vinod JosephPartner | Mumbai
Paridhi Jain
Paridhi JainSenior Associate | Mumbai
Akhil Ganatra
Akhil GanatraAssociate | GIFT City

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In October 2022, an Expert Committee led by Dr. M.S. Sahoo, former Chairperson of IBBI, submitted a report to IFSCA, with recommendations for a legal framework that would facilitate the incorporation of Variable Capital Companies (“VCCs”) in IFSCs. The Expert Committee proposed that the VCC regime should be introduced through amendments to the International Financial Services Centres Authority Act, 2019, instead of through standalone legislation or amendments to the Companies Act, 2013.

The Department of Economic Affairs (“DEA”) has now published the draft International Financial Services Centres Authority (Amendment) Bill, 2026 (“Draft Amendment Bill”), which inserts Chapter III-A into the IFSCA Act to provide a legal framework for the incorporation of VCCs. We have reviewed and analysed the Draft Amendment Bill in our previous Update dated June 15, 2026. In this Update, we have compared the VCC structure proposed by the Draft Amendment Bill with VCC frameworks in the Dubai International Financial Centre (“DIFC”), Singapore and Mauritius.

Read the detailed update here

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