Global Investing for Indian Portfolios: Allocating Across UCITS, Private Markets, and the Magic of GIFT City

By Priyesh Ranjan, Founder & CEO – Valura.Ai

Allocating across UCITS, private markets, and the magic of GIFT City

In my years managing investments for a multi-billion-dollar single-family office and serving as CFO of a Nasdaq-listed technology company, one portfolio mistake has stood out consistently: geographic concentration.

Indian equity markets have delivered strong domestic returns over the past decade. However, India accounts for roughly 3% of total world market capitalization. Keeping your entire net worth in domestic assets cuts you off from the remaining 97% of global investable wealth.

Three practical realities make international allocation necessary:

First, currency movement. Over the long run, the Indian rupee has depreciated against the US dollar by an average of 3% to 5% each year, driven by structural inflation and interest rate gaps. Over the past twelve months alone, the rupee dropped by more than 8% against the dollar. During that same window, outbound remittances under the Reserve Bank of India’s Liberalised Remittance Scheme (LRS) rose 67% to reach $41.6 billion in FY25. When you hold assets in foreign currency, you earn two returns: the growth of the underlying asset and the appreciation of the currency relative to the rupee. If an offshore asset earns a return R_USD, your realized rupee return R_INR expands along with the currency shift Δ_FX:

R_INR = (1 + R_USD)(1 + Δ_FX) − 1

Second, missing industries. The Indian exchanges offer deep liquidity in banking, auto manufacturing, consumer retail, and IT services. Yet they offer virtually no exposure to the primary engines of modern global growth: advanced semiconductor fabrication, foundational artificial intelligence development, cloud hyperscalers, and commercial space exploration. You cannot buy these businesses on domestic exchanges.

Third, family expenses. Many Indian families now pay foreign university tuition, travel internationally every year, or support children settling abroad. When your future expenses are in US dollars, keeping your wealth entirely in rupees creates a severe currency mismatch. Paying for foreign tuition with depreciated rupees raises your real cost every semester. Holding assets in foreign currency matches your wealth to where you will actually spend it.

Public markets, US estate tax, and the UCITS structure

Most investors start investing abroad by buying US stocks or US-listed ETFs. Direct ownership of American equities presents an unexpected tax hazard that catches many families unprepared.

The IRS classifies resident Indians and returning NRIs who have surrendered their green cards or US work visas as non-resident aliens. For non-resident aliens, the exemption limit for US-situs assets, which include shares in American corporations, is only $60,000.

If an Indian investor dies holding direct US stocks valued above $60,000, the estate faces a federal tax rate of up to 40% on every dollar above that boundary. A $500,000 direct equity portfolio carries a potential estate tax bill of nearly $176,000 before the heirs can access the account.

To solve this problem, institutional allocators use UCITS funds. UCITS stands for Undertakings for Collective Investment in Transferable Securities. Regulated by European Union directives and typically domiciled in Ireland or Luxembourg, these funds follow strict liquidity rules, independent custodial safeguards, and the 5/10/40 diversification mandate that prevents excessive single-stock concentration.

For non-US investors, Ireland-domiciled UCITS ETFs provide two major structural benefits:

First, an Irish UCITS fund is legally a European asset, not a US-situs asset. Even if the fund tracks the S&P 500 or holds American tech giants, the legal wrapper sits in Ireland. Because of this, it is entirely exempt from US estate tax, eliminating the 40% liability.

Second, Irish funds reduce dividend tax drag. The tax treaty between the US and Ireland lowers the dividend withholding tax on US corporate payouts from 30% down to 15%.

In addition, you can choose the accumulating share class of a UCITS fund. Rather than paying out quarterly cash dividends that create immediate domestic tax events and foreign remittance fees, accumulating funds automatically reinvest gross dividend income directly back into the fund net asset value. Core examples include CSPX for the S&P 500 and VWRA for global equities.

Private markets: pre-IPO secondaries and structured notes

Public equities and fixed income form the base of an offshore portfolio. To earn returns that do not move in step with public markets, we also allocate capital into private market assets.

Pre-IPO secondaries

Fast-growing technology businesses stay private far longer than they used to. Companies that would have gone public twenty years ago now achieve their strongest growth stages within the private market.

Through late-stage secondary transactions, investors can buy shares in private leaders like SpaceX, Anthropic, and Perplexity before their initial public offerings. These investments are held through regulated Special Purpose Vehicles (SPVs). Because early employees and venture capital funds frequently seek liquidity ahead of a public listing, secondary shares often trade at a noticeable discount to recent primary funding valuations.

Executing these deals requires rigorous legal screening. You must evaluate share classes, liquidation preferences, and company transfer covenants, including rights of first refusal. Sourcing secondaries through regulated platforms prevents the settlement failures and share validity problems common to informal broker networks.

Structured products

Structured notes combine a fixed-income bond issued by a global bank with a derivative option overlay, creating a contractual financial payout.

Capital-protected notes guard your principal while giving you access to market gains. The issuer puts most of your capital into a zero-coupon bond that matures to par at term, while using the remainder to purchase call options on an index or equity basket. If the reference market rises, you share in the upside; if markets fall, the bond repays your full original principal at maturity.

Autocallable yield notes function well in range-bound markets. They pay regular coupons, typically targeting 10% to 19% per year, as long as the underlying stocks stay above a set barrier level. These structures carry downside barrier buffers set 20% to 40% below the starting asset price. Unless an underlying asset drops through that downside buffer at maturity, your principal remains intact and your coupons are paid in full.

Building a global book through GIFT City and Valura

Executing an offshore investment strategy used to mean heavy administrative friction: opening foreign bank accounts, routing international wires, tracking Tax Collected at Source (TCS), and compiling manual Schedule Foreign Asset (FA) filings for annual tax returns.

The International Financial Services Centre (IFSC) at GIFT City, regulated by the International Financial Services Centres Authority (IFSCA), changed this framework. Operating as an international financial zone on Indian soil, GIFT City lets domestic residents remit capital under the RBI’s LRS route directly into Indian-domiciled international custody accounts, without having to open an account abroad.

We built Valura (Valura.ai) to serve as the institutional operating platform across this corridor. Dual-regulated by the IFSCA in GIFT City and the SCA in the UAE, Valura places client assets in segregated custody with First Abu Dhabi Bank and licensed GIFT City custodians like HDFC Bank and SBI-SG, completely separate from our operating balance sheet.

Valura provides access to more than 100,000 instruments across 90+ markets and 22+ exchanges. Through our Exclusives Desk, we have opened late-stage private equity deals and secondary shares in companies like Databricks and Stripe, as well as bank-issued structured notes, starting at a $2,000 entry point. For public markets, we support fractional equity investments starting at $0.01.

We combine this asset access with institutional research, portfolio diagnostics, and automated compliance tools. Our Compass tool models cross-border family liabilities across currencies, and our platform automatically prepares one-click Schedule FA disclosures, capital gains statements, and TCS tracking reports for Indian tax filings. Over 1,000 wealth advisors, financial planners, and chartered accountants have already onboarded with Valura, representing an asset pipeline of over ₹3,000 crore.

Four steps to build your global allocation

For advisors structuring a global portfolio, I recommend this four-step sequence:

1. Audit existing US holdings. Identify direct US equity positions that exceed the $60,000 threshold and transition them into Ireland-domiciled UCITS ETFs to eliminate US estate tax liability.
2. Form your public core with accumulating UCITS funds. Use Irish index ETFs to benefit from the 15% dividend withholding treaty rate and automatic dividend compounding.
3. Introduce an alternative sleeve. Allocate 10% to 20% to pre-IPO secondaries and structured notes to secure private market growth and defined downside protection.
4. Execute via GIFT City. Use regulated platforms like Valura to keep asset custody safe and local, access global markets, and automate your annual tax reporting.

Priyesh Ranjan
Founder & CEO – Valura.Ai

Priyesh is the Founder & CEO of Valura.Ai and 2Cents Capital, he has 20+ years of experience in the world of Finance having managed a multi-billion-dollar single-family office and served as the CFO of a NASDAQ listed company