Form 64C / 64D
AIF Tax Statements
Statements AIFs must produce under Section 115UB for pass-through income. Form 64C goes to each unit-holder; Form 64D is the fund's own filing to the tax department.
Forms 64C and 64D are the statements an AIF produces under Section 115UB of the Income Tax Act and Rule 12CB of the Income Tax Rules, covering income passed through to investors. They apply to Cat I and Cat II AIFs, which have statutory pass-through status (Cat III does not — it's taxed at the fund level instead, and issues a separate certificate; see below).
Form 64C — statement to the unit-holder. The AIF issues one Form 64C to each investor, showing:
- That investor's proportionate share of income by character (short-term capital gains, long-term capital gains, business income, other income, exempt income)
- Any TDS deducted under Section 194LBB
- The financial year the income relates to
- Due date: on or before 30 June following the financial year.
- Generated via the income-tax e-filing portal, verified by the person responsible for paying or crediting the income on the fund's behalf.
- Form 64C is the closest Indian equivalent to a US K-1 — investors use it to populate ITR-2, ITR-3, or ITR-5.
Form 64D — statement to the tax department. A separate filing the AIF makes to its jurisdictional Principal CIT/CIT, consolidating the same income-by-character breakdown across all unit-holders for the year.
- Due date: on or before 15 June following the financial year — earlier than 64C, since it's the figure the 64C statements should reconcile back to.
- Must be verified by an accountant as prescribed under Rule 12CB.
Indian-context notes:
- TDS under Section 194LBB — AIFs withhold 10% TDS on income (other than business income) paid to resident unit-holders, or at the applicable treaty rate for non-residents.
- Mismatches between an investor's Form 64C and their 26AS / AIS are a leading cause of tax notices to LPs — fund admins must reconcile carefully before issuing statements.
- Cat III AIFs don't file 64C/64D at all — they typically issue a separate fund-level tax certificate instead, since their income is taxed at the fund level rather than passed through.
Kapitalyze's Fund OS pre-fills both the Form 64C investor statements and the Form 64D department filing, per LP per FY, from the same distribution-waterfall ledger, so the two always reconcile. A CS or fund accountant should still verify against the current official template before anything goes out to an investor or the tax department.
SEBI's three-tier classification of pooled investment vehicles in India. Determines tax pass-through, leverage limits, and permitted investments.
Fund investor providing capital. In Indian AIFs, structurally a 'Contributor' under the Indian Trusts Act framework — ₹1 crore minimum commitment.
The fund manager — sponsors, raises, deploys, and exits the fund. In Indian AIFs, structured as Investment Manager + Sponsor + Trustee triangle.
Formal notice from a fund's GP to its LPs to fund a portion of their committed capital. Indian AIFs typically issue drawdowns 10–15 business days in advance.
Order in which fund proceeds flow to LPs and GPs. Two main structures: European (fund-as-a-whole) and American (deal-by-deal). Indian AIFs lean European.