Lesson 4 of 5 · PMS Foundation

PMS, Mutual Funds, SIF and AIF — How the Structures Differ

Mutual funds, Specialized Investment Funds (SIFs), PMS and Alternative Investment Funds (AIFs) are all regulated by SEBI but are built differently. This lesson sets them side by side on structure, minimum investment, how they are offered and how the investor is taxed.

Fact-checked 8 October 20263 practice questions in the game

Pooled fund or individual account

The first question to ask of any of these products is what the investor actually holds. In a mutual fund scheme and in a SIF, investors' money is pooled and each investor holds units. A SIF is not a separate kind of institution: it is a product category inside the mutual fund framework, offered by a mutual fund.

PMS is different in kind. Each client has an individual account in their own name and owns the securities in it directly. Nothing is pooled with other clients.

An AIF is again a pooled fund in which investors hold units, but it is privately placed. Every AIF falls into one of three categories: Category I, II or III.

The minimum investment

A SIF needs ₹10 lakh per investor. PMS needs ₹50 lakh per client, brought in as funds or securities. The standard minimum for an AIF is ₹1 crore per investor; employees and directors of the AIF or of its manager may invest from ₹25 lakh. There is no ₹5 crore minimum for AIFs.

Accredited investors, who meet SEBI's income or net-worth tests, are exempt from the SIF, PMS and AIF minimums. All these figures are entry thresholds fixed by regulation: they do not rank the products by risk or by quality.

How each is offered

A mutual fund scheme is offered to the public. An AIF may raise money only by private placement, through a document called the placement memorandum. PMS rests on an agreement between each client and the portfolio manager, which records the service and the fees.

How the tax position differs

Structure drives tax. A mutual fund or SIF investor holds units, and a capital gain arises when the units are redeemed. A PMS client owns the securities, so each sale in the account is the client's own transaction and is taxed in the client's hands.

Category I and II AIFs have pass-through status for income other than business income: it is taxed in the investor's hands as if the investor had made the investment directly. Business income is taxed at the fund level. Category III AIFs have no pass-through, so their income is taxed at the fund level. This is the position as of October 2026.

What they share

None of these structures assures returns, and all carry market risk. A PMS portfolio may also be concentrated. AIF units are usually illiquid and capital can be lost, and a Category III AIF may use leverage, which can magnify losses.

Rules at a glance

Specialized Investment FundPooled, units; ₹10 lakh per investorSEBI Master Circular for Mutual Funds, Chapter 21; accredited investors exempt
PMSIndividual account; ₹50 lakh per client, as funds or securitiesSEBI (Portfolio Managers) Regulations, 2020; accredited investors exempt
AIFPrivately placed pooled fund, units; ₹1 crore per investorSEBI (Alternative Investment Funds) Regulations, 2012; accredited investors exempt
AIF taxCategory I and II: pass-through for income other than business income. Category III, and business income of Category I and II: taxed at the fund levelIncome-tax Act, 2025; position as of October 2026
Illustration

Three investors, three kinds of holding

Kavita invests in a mutual fund scheme: she holds units of a pooled scheme, and a capital gain arises for her when she redeems them. Her brother Rohan opens a PMS account with ₹50 lakh: the account is in his name, he owns the shares in it, and the gain or loss on each sale the manager makes is his.

Their cousin Divya invests ₹1 crore in a Category II AIF offered to her through a placement memorandum. She holds units of a privately placed pooled fund, and its income, other than business income, is taxed in her hands as if she had made the investment directly. All three are exposed to market risk, and none has been assured a return.

Key points

  • Mutual fund schemes and SIFs are pooled, and investors hold units; a SIF sits inside the mutual fund framework.
  • PMS is an individual account in the client's own name, and the client owns the securities.
  • An AIF is a privately placed pooled fund in Category I, II or III.
  • Minimums: SIF ₹10 lakh per investor, PMS ₹50 lakh per client, AIF ₹1 crore per investor; accredited investors are exempt from all three.
  • A PMS client is taxed on each transaction in the account; Category I and II AIFs pass income other than business income through to investors; Category III AIFs are taxed at the fund level.

Common misunderstandings

  • A SIF is not a product outside the mutual fund rules: it sits inside the mutual fund framework and investors hold units.
  • The AIF minimum is not ₹5 crore: the standard minimum is ₹1 crore per investor.
  • Pass-through does not apply to every AIF or to all income: Category III income, and the business income of Category I and II funds, is taxed at the fund level.

Questions people ask

Which of the four are pooled?

Mutual fund schemes, SIFs and AIFs are pooled, and investors hold units. PMS is not pooled: each client has an individual account.

Who is exempt from the minimums?

Accredited investors are exempt from the SIF, PMS and AIF minimums. In an AIF, employees and directors of the AIF or its manager have a lower minimum of ₹25 lakh.

Is a SIF taxed like an AIF?

No. A SIF is a mutual fund product, not a pass-through vehicle.

What this lesson relies on

  • SEBI (Portfolio Managers) Regulations, 2020 (as amended to 3 September 2025)
  • SEBI (Alternative Investment Funds) Regulations, 2012 (as amended to 14 July 2026)
  • SEBI (Mutual Funds) Regulations, 2026 and SEBI Master Circular for Mutual Funds, 20 March 2026, Chapter 21 (Specialized Investment Funds)
  • Income-tax Act, 2025 (taxation of capital gains and of Alternative Investment Fund income)

This lesson was reviewed independently against these sources on 8 October 2026. Rules change: check the current regulation, scheme document or policy wording before relying on any figure. This is education, not advice.

Free learning from the Trustner Group. Trustner Academy is an education initiative of the Trustner Group, whose companies work across insurance broking and investment services, with offices in Bangalore, Guwahati, Kolkata, Hyderabad and Mumbai. Everything here is for learning only — it is not advice, a recommendation or an offer of any product. Scenarios are illustrative. Rules and figures change; check the current regulation, scheme document or policy wording before acting on anything.