If you want to invest in the Nasdaq 100 from India, there is more than one way to do it. You can buy an Indian fund of fund in rupees, or remit money abroad under LRS and buy a UCITS ETF directly.
Most investors comparing this choice end up looking at two funds: the Navi Nasdaq 100 Fund of Fund (the cheapest rupee route by expense ratio) and the iShares Nasdaq 100 UCITS ETF (CNDX), the largest and longest-running UCITS option.
One fact matters before anything else: Navi's fund has been closed to fresh subscriptions, including SIPs, since March 2024, and remains closed as of this writing.
The Navi Nasdaq 100 Fund of Fund invests in the Invesco NASDAQ 100 ETF (QQQM), a US-listed ETF, which makes up 99.8% of the fund. It was launched in March 2022, is bought in rupees with a minimum investment of Rs 100, and charges no exit load.
The iShares Nasdaq 100 UCITS ETF (CNDX) is an Ireland-domiciled ETF that holds the Nasdaq 100 stocks directly. It was launched in January 2010, manages nearly $30 billion, and reinvests all dividends automatically. Indian investors buy it in dollars through the RBI's Liberalised Remittance Scheme (LRS) and hold the units directly in their own name.
Both track the same index, and once you account for what Navi's fund actually holds underneath it, their costs turn out closer than almost any other Indian-fund-vs-UCITS comparison you will find. This piece walks through why, and where the real differences still are.
Table of contents
- What both routes give you
- The structural difference: an Indian FoF holding a US ETF vs a UCITS ETF held directly
- Cost comparison
- Performance: how each fund tracks its index
- Why does the fund keep restricting subscriptions?
- Already hold the fund? What switching involves
- Taxation in India
- Ownership and portability
- Which route is right for you?
- Switching to Paasa
What both routes give you
- The same index. Both ultimately track the Nasdaq 100, the 100 largest non-financial companies listed on the Nasdaq.
- Reinvested dividends. Navi's FoF holds QQQM, which is not accumulating, but the FoF's growth option reinvests everything internally. CNDX is accumulating, reinvesting dividends automatically inside the fund.
- No US estate tax exposure. Neither route holds US-listed securities in your name. Navi's FoF is an Indian mutual fund, and Ireland-domiciled UCITS ETFs are exempt from the US estate tax that applies to US-listed ETFs above USD 60,000.
So the choice is not really about the index or estate tax. It comes down to cost, access, and compliance.
The structural difference: an Indian FoF holding a US ETF vs a UCITS ETF held directly
The Navi FoF is a fund that buys another fund, but that other fund is not India-listed the way some competitors' underlying ETFs are. Your money goes into the FoF, and the FoF buys units of QQQM, a US-listed ETF trading on Nasdaq.
You hold units of an Indian mutual fund in rupees, and you never deal with foreign exchange or LRS yourself, but the fund itself is exposed to US markets one layer down.
CNDX is bought and held in dollars. You remit money abroad under LRS and buy the ETF directly on an exchange, and the units sit in your own brokerage account with a global custodian.
This distinction, an Indian wrapper around a US fund versus direct ownership of an Irish fund, is what the cost and tax sections below come down to.
Cost comparison
Navi's FoF is genuinely the cheapest Indian Nasdaq 100 wrapper by disclosed expense ratio, but the real number includes QQQM's own cost underneath it.
| Cost item | Navi Nasdaq 100 FoF | iShares Nasdaq 100 UCITS ETF (CNDX) |
| FoF expense ratio | 0.16% (direct) / 0.35% (regular) | Not applicable |
| Underlying ETF (QQQM) expense ratio | 0.15% | Not applicable |
| Total recurring cost | ~0.31% (direct) / ~0.50% (regular) | 0.30% TER, all-in |
| Exit load | Nil | None |
| One-time costs | None | Remittance and FX conversion charges, brokerage |
The direct plan's total cost, once you add QQQM's fee, lands almost exactly where CNDX's TER already sits. Most Indian Nasdaq 100 or S&P 500 funds have a materially wider gap, because their underlying layer costs more or their own FoF charge is higher. Navi's combination of a very low FoF fee and a cheap US underlying (QQQM, not the pricier original QQQ) closes most of that gap.
Note: this parity applies to the direct plan only. The regular plan's 0.35% FoF charge plus QQQM's 0.15% brings the total to roughly 0.50%, meaningfully above CNDX's 0.30%.
Performance: how each fund tracks its index
CNDX has a public, verifiable track record here. Comparing its own calendar-year returns against its benchmark from 2016 to 2025, the fund has underperformed by roughly 0.1 to 0.3 percentage points every single year, tracking close to its 0.30% TER. Unlike some other UCITS funds we have covered, CNDX's securities lending income has been minimal in recent years (0.00% in the year to March 2026), so it has not offset the fee the way it has for some peers.
Navi's FoF does not publish a tracking-error figure as directly. Its performance depends on two compounding factors: how tightly QQQM itself tracks the Nasdaq 100 (QQQM is a large, established ETF with a strong replication record), and the FoF's own cash drag and expense layer on top. We could not verify a specific combined tracking figure for the FoF, so treat the total cost figures above as the best available proxy rather than relying on a stated tracking number.
As with any INR-vs-USD comparison, rupee depreciation inflates the FoF's INR returns the same way it would inflate yours in the UCITS route, so raw return numbers are not a fair basis for comparison. Past performance is not indicative of future returns.
Why does the fund keep restricting subscriptions?
SEBI caps the entire Indian mutual fund industry's overseas investments at USD 7 billion. When the industry hits the cap, fund houses must stop taking fresh money.
The Navi Nasdaq 100 Fund of Fund was suspended for fresh subscriptions from March 28, 2024, following an AMFI communication directing mutual funds to stop inflows into schemes investing in overseas ETFs.
The suspension covered lumpsum investments, switch-ins, and new SIP or STP registrations. Navi's own Scheme Information Document, dated as recently as May 2025, states the scheme remains suspended until further notice.
What this means for you in practice:
- This fund has been closed to fresh lumpsum and new SIP registrations for over two years as of this writing. If you already had a SIP running before the suspension, its current status is not clear from public documents.
- Even if the fund reopens, whether it stays open depends on the industry's overall headroom under the USD 7 billion cap, which no single AMC controls.
The UCITS route does not have this problem. Your LRS limit of USD 250,000 per financial year is your own individual limit under RBI rules. It does not depend on what other investors do.
Already hold the fund? What switching involves
If you already hold the Navi FoF, switching is a decision to make deliberately, not in a rush. Three things to know:
1. Redeeming triggers capital gains.
Selling your units is a taxable event. Units held over 24 months are taxed at 12.5% LTCG; units held under 24 months are taxed at your slab rate.
2. There is no in-kind path from a mutual fund.
Mutual fund units cannot be transferred to a foreign brokerage. The only path is redeem, remit, and repurchase. You can stagger this over months to average out currency conversion and market timing.
3. There is no exit load to plan around.
Unlike most funds in this series, Navi charges no exit load at any holding period, so timing your redemption around a load window is not a consideration here. If you have already decided to switch, there is no cost reason to wait: the only timing question left is whether your units have crossed the 24-month mark for LTCG treatment.
Taxation in India
For Indian residents, the tax treatment of the two routes is close.
| Navi Nasdaq 100 FoF | UCITS Nasdaq 100 ETF | |
| Long-term holding period | 24 months | 24 months |
| LTCG rate | 12.5% | 12.5% |
| STCG rate | Slab rate | Slab rate |
| Schedule FA disclosure | Not required | Required every year you hold |
| TCS on investment | None | 20% on LRS remittances above Rs 10 lakh per year, adjustable against tax |
The genuine difference is compliance, not rates. The FoF requires nothing beyond your normal ITR. The UCITS route requires you to disclose your foreign holdings in Schedule FA every year, and non-disclosure carries significant penalties under the Black Money Act.
Ownership and portability
The FoF is an Indian mutual fund holding, in rupees. If you move abroad, you can usually continue holding, but fresh investments as an NRI depend on the fund house's policy for your country of residence.
CNDX units are held in a global brokerage account in your name. If you move from India to Dubai, Singapore, or London, the holding moves with you: you update your residency with the broker and carry on.
If you are planning to move to the US, note that both Indian funds and UCITS funds face the PFIC treatment once you become a US person.
Which route is right for you?
For a new investor deciding today, this is not really a two-way choice. The Navi FoF is currently closed to fresh subscriptions, so unless you already hold it and are adding through an active SIP, this route is not available to you right now regardless of preference.
The Navi FoF fits you if:
- You already hold it and are unaffected by the current suspension, or you are waiting for it to reopen
- When open, you want the lowest-cost rupee route to the Nasdaq 100 and are comfortable with an Indian wrapper around a US-listed fund
The UCITS route fits you if:
- You want to invest new money in the Nasdaq 100 right now, without waiting on any AMC's subscription status
- You want an investment limit that belongs to you rather than depending on industry-wide headroom
- You are investing a meaningful corpus, or there is any chance you will live outside India
The deciding factor is access: right now, only one of these two routes will actually take your money.
Switching to Paasa
If you have decided to move your Nasdaq 100 exposure from the Navi FoF to a UCITS ETF, Paasa handles the parts that usually cause friction:
- Access to US, European, and other global markets: You can add US-listed stocks, European UCITS ETFs, and other international assets from the same account.
- Seamless funding and LRS: Remit, convert, and buy the UCITS ETF in one flow, with LRS compliance handled within the platform.
- Compliance advantage: Get all Indian tax and disclosure documents generated for you at tax time.
