GIFT IFSC is the International Financial Services Centre in GIFT City, Gandhinagar, India. It is a regulated financial jurisdiction supervised by the International Financial Services Centres Authority (IFSCA), not a retail aircraft-loan product. Within its rules, authorised Finance Companies, Finance Units and, in some structures, Banking Units or approved special purpose vehicles (SPVs) can acquire, hold, finance and lease aircraft and specified aviation assets to airlines or other permitted lessees.
The commercial result is usually a lessor or financing vehicle owning or funding an aircraft, then leasing it under an operating, financial or hybrid arrangement. The structure can include a purchase, a lease-in, a sale-and-leaseback, an SPV and cross-border funding. Tax, customs, registration, capital and approval consequences depend on the exact parties, asset route and date of the transaction.
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What GIFT IFSC means for aircraft transactions
GIFT IFSC is a jurisdiction with its own regulatory framework for international financial services. IFSCA authorises and supervises eligible entities that conduct permitted activities there. Aircraft leasing is one of those activities; the framework treats operating leases, financial leases and hybrids as distinct forms of aircraft business.
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1Fix the driver behind crashes, sound loss and screen glitches2Clear out junk files and repair common Windows errors3Scan for outdated or missing drivers - takes under a minuteThe covered assets are broader than a single aircraft model. Depending on the authorisation and applicable rules, they can include aircraft, helicopters, engines, parts, aircraft ground-support equipment and aviation-training simulation devices. The legal permission belongs to the authorised entity and its approved activity, not automatically to every company with a GIFT City address.
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The framework was built on an October 16, 2020 government notification that recognised aircraft leasing, including operating, financial and hybrid leases, as a financial product in an IFSC. IFSCA’s aircraft-leasing resource page identifies a revised framework dated February 26, 2025, including an amendment concerning transactions with persons resident in India. Always use the consolidated rules and current circulars for a live deal.
Start with the IFSCA aircraft-leasing framework and resource index for the current list of regulations, forms, FAQs and registered entities.
How an aircraft financing structure works
There is no single mandatory transaction chain. The following model shows the roles that commonly appear without implying that every deal uses all of them.
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- Choose the authorised vehicle. A Finance Company or Finance Unit registered with IFSCA may act as lessor or financing vehicle for permitted aircraft-leasing activities. A Banking Unit can have separate permissions under the IFSCA Banking Regulations. An SPV may be used where the Finance Company rules and IFSCA permission allow it.
- Acquire or fund the asset. The vehicle may purchase an aircraft or eligible related asset, finance its purchase, or lease the asset in before leasing it onward. Funding can come from equity, debt, secured facilities or other permitted sources, with currency and interest-rate exposure documented in the transaction.
- Contract with the lessee. An airline or another permitted operator signs an operating lease, financial lease or hybrid agreement. The documents set rent, maintenance, insurance, records, use restrictions, default remedies, return conditions and any purchase option.
- Manage the asset through its life. The lessor or financing vehicle monitors maintenance status, airworthiness records, insurance, registration, technical reserves, payment performance and compliance with the lease and applicable aviation rules.
- Handle return, sale or refinancing. At expiry or default, the parties may return the aircraft, extend the lease, sell it, refinance it or complete a purchase option, subject to the contract, registration rules and lender protections.
Sale-and-leaseback is a related structure: an airline sells an aircraft to a lessor or financing vehicle and immediately leases it back. It can release capital while preserving use of the aircraft, but the sale price, lease liability, maintenance obligations and accounting treatment require separate analysis.
Operating lease, financial lease and hybrid: what changes?
IFSCA’s framework permits all three forms. The label alone does not determine tax, accounting or commercial risk; those results follow from the contract, economic substance, parties and applicable law.
| Issue | Operating lease | Financial lease | Hybrid or tailored structure |
|---|---|---|---|
| Typical economics | Lessor generally retains more residual-value exposure and expects the aircraft to be returned or re-leased. | Lessee commonly bears more of the asset’s economic risks and may have a purchase option or obligation. | Terms combine features of both; the allocation must be read from the documents. |
| Maintenance and technical risk | Often allocated through return-condition clauses, reserves and lessor oversight. | More risk may sit with the lessee, depending on covenants and maintenance arrangements. | Can divide risk by component, period or event. |
| Term and termination | May provide scheduled return and more flexibility to place the aircraft with another operator. | Usually designed around long-term financing economics and stricter payment commitments. | Negotiated; do not infer rights from the heading alone. |
| Residual value | Material to the lessor’s pricing and remarketing plan. | May be concentrated with the lessee or shared by contract. | Can use minimum-value guarantees, options or sharing mechanisms. |
| Tax and customs | Not determined by the name of the lease. Analyse the asset route, parties, use, import status and current legislation. | ||
For any proposal, compare who bears residual-value and maintenance risk, the lease tenor, early-termination rights, purchase or return obligations, ownership and registration arrangements, funding currency, lessee credit and enforcement rights. Those are decision questions, not automatic consequences of selecting a legal label.
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Who can conduct the business?
Finance Companies and Finance Units
The aircraft framework provides for lessors registered as a Finance Company or Finance Unit. The entity must fit the eligible form, obtain the relevant registration and comply with IFSCA conditions, including capital and ongoing reporting requirements applicable at the time of approval.
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The GIFT IFSC FAQ asks, “Can an IFSC Banking Unit (IBU) undertake finance leasing operations?” It answers that an IBU has been permitted to undertake equipment leasing, including aircraft leasing, under the IFSCA Banking Regulations. This is a distinct route from a Finance Company or Finance Unit acting as the aircraft lessor, so the IBU’s permissions and prudential rules must be checked separately. See the GIFT IFSC aircraft-leasing FAQ.
Special purpose vehicles
IFSCA’s Finance Company (Amendment) Regulations, 2026, notified in May 2026, added provisions for SPVs undertaking permitted leasing or financing activity, subject to IFSCA permission and the applicable capital provision. The amendment defines a TCSP as “an entity authorised under the International Financial Services Centres Authority (TechFin and Ancillary Services) Regulations, 2025, to provide TCSP services.” In practice, an SPV can ring-fence an aircraft or transaction, but the amendment does not create automatic approval, eliminate capital requirements or guarantee a tax benefit.
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The 2026 change amends the Finance Company regulations; it does not replace the aircraft-specific framework. Read both together and check for later amendments before signing documents. The official text is available in the IFSCA (Finance Company) (Amendment) Regulations, 2026.
Setting up an aircraft-leasing operation in GIFT IFSC
The official FAQ is a practical starting point, but application forms, promoter criteria, capital thresholds and documentary requirements can change. Treat the following as a sequence for planning rather than a substitute for current regulatory advice.
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Scan for outdated or missing drivers - takes under a minuteDriver Scan →Clear out junk files and repair common Windows errorsFree Scan →- Define the activity and asset scope. Decide whether the business will conduct operating leases, financial leases, hybrids, sale-and-leasebacks, financing or related permitted activities. Identify whether aircraft, engines, parts or other eligible equipment are involved.
- Select the legal route. Determine whether a Finance Company, Finance Unit, Banking Unit or an SPV is appropriate. Map ownership, control, funding, governance and any service-provider arrangements.
- Secure an IFSC presence. The FAQ describes identifying office space in GIFT City and obtaining relevant Special Economic Zone clearances. Confirm the current premises and SEZ process with the authorities.
- Incorporate and prepare governance. Form the entity, appoint responsible officers, establish risk, compliance, accounting and technical-asset controls, and prepare evidence of financial capacity and fit-and-proper eligibility where required.
- Apply through the required authorities. The FAQ refers to applications to the SEZ authority and IFSCA. Use the latest application forms and instructions on the IFSCA aircraft-leasing page rather than relying on an older checklist.
- Build aviation and treaty compliance into documents. The FAQ says an IFSC entity intending to undertake aircraft leasing must conform to the Cape Town Convention and Protocol. Registration, international-interest filings, repossession rights, deregistration powers and records should be addressed before funding closes.
- Obtain transaction-level approvals. Confirm whether a proposed lessee, resident counterparty, asset route, SPV or financing instrument needs a specific permission or notice. The February 2025 framework update includes provisions concerning transactions with persons resident in India.
Tax, customs and GST: why the answer is conditional
GIFT IFSC is not a blanket “tax-free” zone for every aircraft transaction. Tax and customs treatment depends on the asset’s movement, the lessor and lessee, the operator’s status and use, import or export steps, lease terms, effective dates and statutory conditions.
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The GIFT IFSC FAQ describes scenarios in which leasing an aircraft or engine to an Indian airline can attract integrated GST under forward charge at the rate stated in that FAQ. It also describes customs treatment conditional on an aircraft being imported by or for the operator for scheduled air operations. These are scenario-based statements, not a universal rate or exemption for every lease.
An IFSCA-hosted EY presentation, Aircraft Leasing from GIFT IFSC: Tax Benefits, summarises aircraft-related income-tax exemptions or tax-holiday conditions as well as customs and GST charges in particular cases. A summary presentation cannot replace the legislation, notifications and transaction-specific opinion. Before pricing a lease, verify current law, the relevant financial year, eligibility conditions, connected-party rules, withholding and indirect-tax treatment with qualified Indian tax and customs advisers.
- Identify who imports the aircraft or engine and under which customs procedure.
- Confirm whether the lessee is an Indian airline, another resident, or a non-resident and whether scheduled-air-operation conditions apply.
- Check where the asset is delivered, registered, operated and returned.
- Test income-tax, GST, customs, withholding, transfer-pricing and permanent-establishment consequences separately.
- Put responsibility for filings, exemptions, certificates, changes in law and unexpected tax into the lease and financing documents.
What the 2025 and 2026 changes mean
| Date | Development | Practical meaning |
|---|---|---|
| October 16, 2020 | Government notification recognised aircraft leasing, including operating, financial and hybrid leases and specified aviation assets, as an IFSC financial product. | Established the policy foundation later reflected in the aircraft-leasing framework. |
| February 26, 2025 | IFSCA’s revised Aircraft Lease framework and related amendment were listed on its aircraft-leasing page. | Use the revised framework, including its provisions on transactions with persons resident in India, for current structuring. |
| May 2026 | Finance Company (Amendment) Regulations added SPV-related provisions and defined TCSPs. | May permit an approved SPV to undertake permitted leasing or financing, subject to IFSCA permission and capital rules; it does not replace the aircraft framework. |
Risks and questions to resolve before funding
- Regulatory scope: A structure can fail if the entity’s registration does not cover the proposed activity or counterparty.
- Lessee credit: Rent, maintenance reserves and repossession economics depend on the operator’s financial strength and jurisdiction.
- Residual value: Aircraft prices, engine condition, technology changes and remarketing demand affect the lessor’s return.
- Technical compliance: Airworthiness, maintenance records, parts traceability and return condition can create large unexpected costs.
- Currency and interest rates: Mismatches between lease income, debt service and asset value can change cash flow materially.
- Enforcement: Cape Town Convention protections help only when registrations, declarations, consents and local procedures are correctly implemented.
- Tax change: A legislative or customs change can alter the economics after signing, so indemnities and change-in-law clauses matter.
- SPV administration: An SPV still needs governance, books, reporting, capital and authorised service providers; it is not a compliance shortcut.
How to evaluate a proposed GIFT IFSC aircraft deal
- Obtain the current IFSCA aircraft framework, Finance Company rules and any Banking Regulations relevant to the chosen entity.
- Prepare a one-page flow diagram showing seller, lessor or SPV, lenders, airline, importer, operator, registries and cash movements.
- Classify the lease economics using residual-value, maintenance, purchase-option and return-condition tests rather than the title of the contract.
- Model base, delayed-delivery, default, early-return and resale cases, including currency and interest-rate changes.
- Ask tax and customs advisers for a written analysis tied to the exact asset route, parties, dates and statutory conditions.
- Confirm Cape Town registrations, insurance, technical records, repossession and deregistration procedures before closing.
- Recheck every approval, form and eligibility condition immediately before execution because the framework and guidance can be amended.
Market-data limitation
IFSCA’s aircraft-leasing page lists an activity-statistics entry described as “as on May 31, 2023” and dated March 31, 2024. No newer aggregate activity figure is established here, and the underlying figures should not be presented as a current market total. A dated snapshot cannot by itself show today’s fleet, transaction volume or market share.
Bottom line
Aircraft financing through GIFT IFSC is a regulated commercial leasing and financing structure, not a consumer loan and not an automatic tax shelter. An authorised entity acquires or funds an eligible aircraft asset, leases it under an operating, financial or hybrid arrangement, and manages aviation, credit, technical, regulatory and tax obligations over the asset’s life. The February 2025 aircraft framework and May 2026 SPV amendment expand the structuring context, but each transaction still requires current IFSCA permissions and specialist tax, customs, aviation and legal analysis.
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