Data Centre REIT &
InvIT Monetisation
Advisory for AAA-rated corporates and infrastructure owners monetising data centre portfolios through REITs and InvITs. Navigate Section 115UA conversion, cross-border investor tax, and CPSE REIT structures.
DC-to-REIT Conversion
Precision execution under Section 115UA for single-level tax pass-through status. We utilize Section 47(xvii) and Section 49(2AC) for tax-neutral transfer of specific real estate assets to the SPV.
InvIT Formation
Securing exact infrastructure classification for digital assets. We establish the Trust structure, model Distributable Pay-out (DPU), and optimize frameworks to handle elevated leverage up to 70%.
Cross-Border Investor Tax
Optimizing the DTAA Withholding Tax (WHT) footprint for foreign LPs. We specifically structure units to trigger the Section 10(23FE) absolute tax exemption for Sovereign Wealth Funds (SWFs) and Pensions.
Core Advisory Deliverables
Our practice architects the exact tax-neutral mechanics required to extract high-yield data centre infrastructure from corporate balance sheets into listed or private yield vehicles.
DC-to-REIT Conversion
Comprehensive feasibility testing and SPV architecture. We deploy Section 47(xvii) for Capital Gains Tax (CGT) deferral, optimize stamp duty during asset transition, and coordinate the SEBI application.
InvIT Formation & DPU Modelling
Architecting the sponsor-trust dynamic to secure specific infrastructure status. We provide rigorous Distributable Pay-out (DPU) modelling accounting for debt servicing under elevated leverage thresholds.
Cross-Border Investor Structuring
Maximizing post-tax yield for foreign investors. We manage precise FEMA compliance and design structures that allow Sovereign Wealth Funds to seamlessly claim Section 10(23FE) exemptions.
CPSE REIT (Budget 2026)
Early-mover advisory for public sector enterprises. We align asset monetization strategies directly with the specialized Central Public Sector Enterprise (CPSE) REIT framework introduced in Budget 2026.
Dual-Benefit Structuring
Combining multiple tax shields simultaneously. We model scenarios where the pass-through benefits of a REIT intersect with jurisdictional tax holidays, specifically leveraging Section 80LA.
GAAR Resilience
Ensuring complex conversions survive intense scrutiny. Every REIT and InvIT formation strategy is stress-tested against the General Anti-Avoidance Rule (GAAR) to prevent unwinding.
Monetisation & Yield Structuring Lifecycle
Transitioning a physical data centre to a financial yield instrument requires surgical precision. Our methodology maps the exact regulatory stepping stones from internal carve-out to institutional listing.
Asset Carve-out & SPV Formation
We isolate the data centre or telecom infrastructure from the broader corporate balance sheet. Focus is placed on minimizing the initial stamp duty and utilizing Section 47(xvii) to achieve absolute CGT deferral upon transfer to the SPV.
Trust Formation & Regulatory Approval
Structuring the overarching Trust architecture and formalizing the Sponsor-Manager relationship. We orchestrate the SEBI listing application and rigorously model the DPU under Section 115UA’s pass-through provisions to ensure yield viability.
Cross-border Yield Optimisation
Following formation, the focus shifts to maximizing the return for foreign institutional investors. We implement advanced DTAA mapping to suppress WHT on interest/dividend distributions and secure binding Section 10(23FE) exemptions for SWFs.
Who Needs REIT & InvIT Advisory?
Our practice serves the major players in India’s digital infrastructure boom, facilitating massive capital recycling efforts for operators and deep-pocket investments for global funds.
| Client Profile | Indicative Scale | Strategic Imperative & Solutions |
|---|---|---|
| Indian DC Operators (Private) | ₹2,000 Cr+ portfolio; 50+ MW | Executing DC-to-REIT conversions to achieve capital recycling, unlocking liquidity via Section 115UA while retaining operational control as the Sponsor. |
| Telecom / IT Infrastructure Cos. | Fibre/tower assets ₹10,000 Cr+ | Structuring InvITs specifically for massive infrastructure portfolios, utilizing the distinct advantage of elevated leverage (up to 70%). |
| Global Hyperscalers (India DC) | USD 500M+ India DC investment | Navigating complex Cross-Border Investor structuring, FEMA compliance, and fiercely negotiating DTAA WHT reductions on repatriated yields. |
| Sovereign Wealth Funds / Pensions | India allocation USD 200M+ | Targeting pure yield optimization via direct REIT/InvIT unit investment, structurally underpinned by the absolute tax protection of Section 10(23FE). |
Implementation & Compliance
We do not stop at the advisory memo. Strategix executes the necessary filings and coordinates seamlessly across interconnected tax and regulatory frameworks.
| Service Area | Filings & Cross-Vertical Connections |
|---|---|
| SEBI / Regulatory Filings | Preparation of the core tax modules required for the REIT/InvIT Offer Document and executing mandatory ongoing SEBI compliance filings. |
| Investor Tax Certificates | Issuing specific tax certificates to unitholders, providing the precise breakdown of dividend, interest, and capital repayment for Section 115UA tracking. |
| Transfer Pricing Scrutiny | Vertical 13 Establishing rigorous Form 3CEB documentation to defend complex related-party transactions occurring between the Sponsor entity and the listed REIT. |
| Green Data Centres | Vertical 10 If the infrastructure meets sustainability metrics, integrating SEBI Green Bond frameworks to access ESG-specific financing pools. |
Every referral begins with a confidential,
no-obligation assessment.
CA firms, law firms and professional services partners — contact Shreyansh Verma directly to discuss referral arrangements, co-advisory engagements, or a specific client mandate.