The short answer. Portfolio management is a SEBI-regulated service with a statutory minimum of ₹50 lakh per client. For a non-resident it sits on top of the FEMA machinery — the right account, the right custody arrangement, and the documentation that goes with them. The structural point that matters most is that a PMS investor owns the securities directly, which changes when tax arises.
What SEBI requires of the manager
A portfolio manager must be registered with SEBI, must maintain a minimum net worth, must appoint a compliance officer, and must place client assets with an independent custodian — so the firm that manages the money never holds it. The minimum investment per client is ₹50 lakh, raised from ₹25 lakh in 2020.
A discretionary portfolio manager may not invest client money in unlisted securities, and investments in securities of the manager's own related parties are capped as a proportion of a client's assets. Those are protections, and they are worth knowing you have.
What changes for a non-resident
The service is the same; the plumbing is not. It runs through the account structure described in our piece on NRE and NRO accounts, with the consequences for repatriation that follow from which account funded it. Tax is commonly deducted at source rather than settled at filing. Documentation is heavier.
Whether a particular portfolio manager can onboard a non-resident at all is a question about that manager — its custodian arrangements, its banking relationships and the jurisdictions it is able to deal with. It is a fair question to ask first, and a straight answer is a reasonable expectation.
The structural point: you own the shares
In a mutual fund you own units of a pooled vehicle, and the manager's trading inside it creates no tax event for you. In a portfolio management service the securities are held in your own name, so when the manager sells, you have realised a gain — in that financial year, whether or not you withdrew anything.
For a non-resident this compounds. The gain is realised in India, tax is often withheld at source, the proceeds land in a particular account with particular repatriation consequences, and the same income may need declaring where you live. Portfolio turnover is therefore not a question of style. It is a question about your cash, your paperwork and your filing obligations in two countries.
It is a reason to ask a prospective manager how often they trade before asking what they returned. Our own approach holds 20 to 36 businesses for 5 to 7 years — the reasoning is set out in our investment philosophy and the strategy is described here.
Questions worth asking any portfolio manager
- Can you onboard a non-resident in my country of residence, today?
- Who is the custodian, and will the account be in my name?
- What was portfolio turnover over the last twelve months?
- How are fees charged, and is there a performance fee, a hurdle and a high-water mark?
- What does the disclosure document say about conflicts and about litigation?
The last one is the most revealing, and the document is public. Ours is on our disclosures page, and who the service suits — and who it does not — is set out on Who Should Invest With Us.
Before you act on any of this
This is general information about how the rules work, not investment, tax or legal advice, and not a recommendation to buy or sell anything. Your position depends on your residential status, your country of residence and your own circumstances, and the rules change. Take advice from a qualified professional in both countries before you act. Nothing here is an offer, and Redberyl Investment Managers LLP gives no assurance of any return.
Sources
- SEBI — Portfolio Management Services — checked 29 September 2026
- Income Tax Department — Capital Gains — checked 29 September 2026
- Reserve Bank of India — FEMA and NRI accounts — checked 29 September 2026
More in this series: NRE and NRO accounts · how the tax works · taking money out · PMS and non-residents