Master prompt
Source of funds dossier + FEMA / LRS / ODI compliance for NZ investor visas
Indian-side compliance for outbound capital: RBI LRS USD 250K/FY (individual), ODI for corporate path, 15CA/15CB, PMLA / Black Money Act disclosure, NZ AML/CFT receiving-bank scrutiny. Critical for AIPV (NZ$5M) and EWV (NZ$100K-NZ$500K).
NZInvestor visaSource of fundsFEMALRSODI15CA15CBAML
Build a source-of-funds (SoF) dossier for [CLIENT_NAME] for the NZ investor visa application (AIPV or EWV). Both INZ and the receiving NZ bank under NZ's AML/CFT Act 2009 will scrutinise the origin and trace of funds. India-side FEMA and tax law govern the outbound side.
CLIENT SUMMARY
- Intended NZD remittance: [INTENDED_REMITTANCE_NZD]
- Principal wealth sources: [PRINCIPAL_WEALTH_SOURCES]
- Wealth-build timeline: [TIMELINE_YEARS]
- Remittance vehicle: LRS — personal route
- Indian tax status: [INDIAN_TAX_STATUS]
- Known regulatory flags: None
DISCLAIMER FRAME (state up front)
This is consultant advisory only. Indian foreign-exchange (FEMA), income tax, and PMLA matters sit outside the IAA scope of practice. Engage:
- Indian Chartered Accountant (CA) for tax compliance + 15CA/15CB
- Indian Authorised Dealer (AD) Bank for FEMA-compliant remittance
- Indian counsel for any regulatory / litigation matters
- NZ-side AML lawyer + NZ accountant for receiving-side compliance
§1 — TWO-SIDED COMPLIANCE FRAME
INDIAN SIDE (outbound):
(a) FEMA 1999 — governs outbound remittance from India
(b) Liberalised Remittance Scheme (LRS) — Master Direction on LRS, RBI
(c) Overseas Investment (OI) Rules + Master Direction on OI (Aug 2022)
(d) Income Tax Act 1961 s.195 + Rule 37BB — Form 15CA/15CB
(e) Prevention of Money Laundering Act 2002 (PMLA)
(f) Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act 2015
(g) GST Act 2017 (if business sale source — GST on consideration)
NZ SIDE (inbound):
(h) AML/CFT Act 2009 — applies to NZ banks, lawyers, accountants accepting funds
(i) Customer Due Diligence (CDD) + Enhanced Due Diligence (EDD) for HNW
(j) INZ source-of-funds verification under Operational Manual BJ
(k) Financial Markets Authority (FMA) — for licensed investment activity
(l) Tax Information Exchange — FATCA / CRS reporting from receiving NZ bank to NZ IRD and back to India CBDT
§2 — INDIAN LRS — PERSONAL ROUTE
LRS allows resident individuals to remit up to USD 250,000 per financial year (April-March) for permitted purposes, including investment abroad.
For [INTENDED_REMITTANCE_NZD] (assume rough 1 NZD = INR 50 = USD 0.60 — verify FX):
- NZ$5,500,000 ~= USD 3,300,000
- At USD 250K/FY/individual: 13.2 individual-years required
- With spouse + 2 adult children pooling: 4 individuals × USD 250K = USD 1M/FY → 3.3 years minimum
- With multi-year planning: feasible over 3-4 FY
Eligibility:
- Resident individuals only (NRIs use different routes)
- Each remitter must have PAN
- Each remittance must be from KYC-compliant bank account
- Funds must be from declared sources (no cash inflow)
Permitted purposes for AIPV / EWV under LRS:
- "Investment abroad — equity / debt of foreign entity"
- "Maintenance of close relatives abroad" (limited — not the primary lever)
- "Studies abroad" (only for genuine study)
- "Acquisition of immovable property" (subject to FEMA — limited for residential)
- "Other current account transactions" with appropriate purpose code
Documentation per remittance:
- Form A2 (FX declaration)
- Form 15CA (online) — categories per Rule 37BB
- Form 15CB (CA certificate) for remittances above threshold (currently INR 5 lakh per remittance for most purposes — verify)
- Beneficiary bank details in NZ
- Source of funds proof to AD Bank
§3 — INDIAN ODI ROUTE (corporate / business-source)
Overseas Direct Investment (ODI) under Master Direction on OI (Aug 2022) — applies when funds come via an Indian company investing abroad rather than an individual.
Use cases:
- Existing Indian company invests into NZ subsidiary
- Indian holding company funds NZ business acquisition
- Joint venture structures
Key features:
- No annual cap (vs LRS USD 250K) — up to 400% of Indian company's net worth
- Requires UIN (Unique Identification Number) from RBI
- Annual Performance Report (APR) filing
- Form ODI submitted via AD Bank to RBI
- More documentation but no LRS ceiling
If LRS — personal route includes ODI: state the ODI sub-route (automatic vs approval), Indian-company structure required, and quantum vs net worth headroom.
§4 — SOURCE-OF-WEALTH DOCUMENTATION (per wealth source)
For each principal wealth source listed in [PRINCIPAL_WEALTH_SOURCES], document:
(A) BUSINESS SALE (e.g. "Sale of family-owned manufacturing business in Mumbai 2023"):
- Share Purchase Agreement / Asset Purchase Agreement
- Valuation report (Chartered Accountant / Merchant Banker)
- Sale consideration received bank trail (from buyer's account to seller's account)
- Income Tax filed on capital gains (long-term capital gains computation)
- GST clearance / no-due certificate
- Companies House / MCA filings showing share transfer
- Pre-sale company financial statements (last 3-5y) showing business reality
- Photos of factory / staff / products
- Buyer due-diligence reports if available
(B) BUSINESS-RETAINED EARNINGS:
- Audited financial statements (last 10y) showing accumulated retained earnings
- Dividend declarations to shareholders
- Director's Loan Account statements
- Income tax returns for the business + shareholders
- Bank statements showing salary / dividend / loan-repayment outflows from business to shareholder
(C) LISTED EQUITY / MUTUAL FUND PORTFOLIO:
- Demat account statements (CDSL / NSDL) — last 10y
- Broker contract notes for original purchases
- Capital gains computations (long-term + short-term)
- Income tax returns showing dividend / capital gains income
- Mutual fund consolidated statement (CAS) from CAMS / KFintech
(D) PROPERTY SALE:
- Sale Deed (registered)
- Buyer payment trail (cheque / RTGS via banks)
- Capital gains computation + Long-Term Capital Gains tax paid
- Stamp Duty payment evidence
- 26AS showing TDS by buyer (if applicable)
- Original purchase documents (chain of title)
(E) INHERITANCE / GIFT:
- Will / Probate / Succession Certificate
- Donor's source-of-wealth (if gift) — same dossier for donor
- Gift Deed (registered if real estate; declaration for movable)
- Income tax disclosure (Section 56(2)(x) — exempt for close relatives)
(F) SALARY / EMPLOYMENT INCOME:
- Form 16 / Form 26AS for relevant years
- Salary slips
- Employment contracts
- Bank statements showing salary credits
For [CLIENT_NAME]'s [PRINCIPAL_WEALTH_SOURCES], build a source-by-source documentation matrix with target document list per source.
§5 — TRACE-THROUGH-BANKING NARRATIVE
For each major wealth event:
Event 1: [e.g. "Business sale 2023 INR 28 cr"]
- Funds received: [date] into [bank account]
- Deployed to: [investments / further accounts / property]
- Current location: [account holding pre-remittance funds]
Event 2: [...]
The dossier should show an unbroken chain from original wealth event → current account holding remittance-ready funds → outbound remittance to NZ.
NZ banks under AML/CFT EDD will literally ask "where did this money come from, and how did it get into this account?" — the answer must be traceable through bank statements + supporting docs.
§6 — 15CA / 15CB MECHANICS
For each outbound remittance under LRS:
Form 15CA (Information by remitter — online via Income Tax portal):
Part A: small remittances (under INR 5 lakh in FY)
Part B: above threshold, with CA certificate (15CB)
Part C: large remittances with full certification
Part D: not chargeable to tax under DTAA
Form 15CB (CA certificate of nature of remittance):
Issued by a CA in practice; certifies tax position under IT Act + DTAA
India-NZ DTAA in force (1985, amended) — capital gains generally taxable in source state per Article 13
For non-capital-gain remittances (e.g. permitted LRS under "investment abroad"), 15CA/15CB still required documenting the FEMA basis.
§7 — TIMELINE — REMITTANCE SCHEDULE
For [INTENDED_REMITTANCE_NZD]:
Year -1 (12 months pre-visa-grant):
- Sequence wealth-source documentation
- Build SoF dossier
- Plan LRS / ODI allocation across financial years
- Open NZ-side bank account (in-principle)
Year 0 (visa grant + ITA / post-grant):
- Begin remittances under LRS:
Q1 (Apr-Jun): tranche A
Q2 (Jul-Sep): tranche B
Q3 (Oct-Dec): tranche C
Q4 (Jan-Mar): tranche D
- Each tranche with 15CA/15CB, A2, source-of-funds to AD Bank
Year +1: continue remittance if multi-year LRS plan
Year +2 onwards: maintain investment + annual compliance (NZ IR3 + India ITR on Indian-sourced income)
§8 — RECEIVING NZ BANK — AML/CFT EXPECTATIONS
NZ banks will require:
- Identity verification (passport + NZ IRD number once issued)
- Address verification
- Source-of-funds declaration with supporting documents (English translations where needed)
- Purpose-of-account
- Politically Exposed Person (PEP) check
- Sanctions screening
- Ongoing transaction monitoring for unusual patterns
Common AML friction points for Indian-origin HNW clients:
(a) Large round-figure inward remittance from India unsupported by clear documentation
(b) Funds passing through multiple jurisdictions before reaching NZ
(c) Crypto-related origin (NZ banks often won't accept crypto-sourced funds)
(d) Cash-business origin (e.g. Indian jewellery / retail) — extra scrutiny
(e) Politically exposed (relative is government / political party official)
Pre-engagement with NZ bank's HNW / private bank team 2-3 months before remittance avoids friction.
§9 — REGULATORY-FLAG MITIGATION
For each flag in None, state mitigation:
- Income Tax notice (resolved no addition): Get order under s.143(3) + closure proof; disclose proactively to INZ
- GST dispute pending: Document, state position, get counsel's opinion on materiality
- ED / SFIO matter (closed): Closure order + advocate's certificate
- Open litigation: Disclose; INZ may defer until resolution
- PMLA flag (any): Likely terminal — engage Indian counsel before any NZ application
Non-disclosure of known flags = misrepresentation under Immigration Act 2009 — far worse than disclosing.
§10 — INDIAN TAX EXIT PLANNING
If [CLIENT_NAME] is relocating (not just investing passively):
(a) Indian residency under IT Act 1961 s.6 — break in physical presence to become NRI in year of move
(b) Income Tax Clearance Certificate (ITCC) — required if leaving India and tax dues / assessments pending
(c) Sale of Indian assets — capital gains tax at source
(d) NRO / NRE / FCNR account setup
(e) Aadhaar + PAN retention
(f) RNOR status for 2-3 years post-arrival in NZ — Indian tax only on Indian-sourced income
(g) Transitional Resident exemption in NZ (4-year foreign-income exemption) — claim if eligible
§11 — RED FLAGS CHECKLIST
□ Any cash component in wealth-build? (untraceable cash typically not accepted)
□ Any crypto in wealth chain? (most NZ banks won't accept; need to convert + season)
□ Wealth-build timeline matches age / career arc?
□ All Indian tax returns filed for last 10y?
□ Any benami / nominee structures? (illegal under Benami Act; must unwind first)
□ Any unexplained income from Income Tax / GST proceedings?
□ Foreign assets disclosed on Schedule FA of Indian ITR (Black Money Act compliance)?
□ FEMA breaches (e.g. unreported foreign bank account)?
□ Loan-funded remittance? (LRS allows but documentation different; loan must be from declared source)
End with: "DRAFT source-of-funds dossier and FEMA/LRS plan — for Indian CA + NZ AML lawyer + IAA-licensed adviser joint review. The SoF dossier is THE single most-scrutinised element of any AIPV / EWV application; weak documentation here delays / refuses applications regardless of investment quality. Allow 6-9 months for dossier build before first remittance. Confirm current LRS limits, ODI rules, 15CA/15CB thresholds, and India-NZ DTAA position with current Indian tax counsel."Unlock the vault to see the full prompt