NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (2024)

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Published on Tuesday, August 27, 2019 by Chittorgarh.com Team | Modified on Sunday, August 9, 2020

NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (2)

NRIs are allowed to invest in equity, equity derivatives, IPOs, Mutual Funds, and bonds in India. Learn about various NRI Trading charges associated with trading and investments in India.

To trade in BSE & NSE in India, an NRI needs multiple accounts based on the segment they choose.

  1. NRI PIS Charges
  2. NRI Bank Account Charges
  3. NRI Trading Account Charges
  4. NRI Demat Account Charges
  5. NRI Custodial Account Charges

Let's understand these accounts and the various charges associated with it in detail:

NRI PIS Permission Charges

Portfolio Investment Scheme (PIS or PINS) is a scheme by RBI which enables NRIs to invest in Stocks, Equity F&O, IPOs and Mutual Funds through BSE & NSE in India. Under this scheme, all the bank transactions are required to be reported to the RBI by the bank.

NRIs can trade on both repatriation and non-repatriation basis. For investments on repatriation basis, NRIs need to open a PIS enabled NRE Bank account and route their trading and investment amount through it. For investments on non-repatriation basis, NRIs need a PIS enabled NRO bank account or NRO account (without PIS) and fund their trading and investment amount through it.

Read NRE Vs NRO account to know the difference between NRE and NRO Bank accounts.

After opening the NRI bank accounts, NRIs need to fill a form called 'Application for designating bank account for PIS' and submit it to their bank. Once approved, the requested (NRE or NRO) bank account is designated as PIS Enabled Account. All transactions from the account are reported to RBI by the bank daily. While registering for PIS, an NRI also needs to appoint a specific branch of the bank as a Designated Bank for PIS. The RBI has authorized only select branches of banks for NRI banking transactions.

An NRI Bank Account is designated as a PIS Bank Account after the PIS approval is received. These accounts also need to be linked while opening an NRI Demat and NRI Trading account.

NRIs need to pay 3 types of charges for NRI PIS Scheme-

NRI PIS Charges

PIS Issuance Charges

This is a one-time fee to be paid while applying for PIS permission. The fee varies between Rs 0 to Rs 500.

PIS Account AMC

This is an annual fee to be paid every year to the bank for maintaining the PIS Account. The fee is charged irrespective of transactions being done in the PIS enabled accounts.

Other PIS Charges

This fee is charged for every buy and sell transaction done using PIS enabled bank accounts. The charges will be levied for every NRE & NRO purchase and sell separately.

Note: The PIS charges vary depending on the bank.

NRI Bank Account Charges

An NRI needs to open NRI Bank Account to manage money, trade and invest in India. NRI bank accounts are classified into two types:

  1. Non-Resident External (NRE) account

    This account is opened with the purpose to facilitate the transfer and manage the income earned abroad to India. The account is rupee dominated account and is fully repatriable i.e. the money held in the account can be transferred to India. The interest earned from the account is tax-exempted.

  2. Non-resident Ordinary (NRO) account

    This account is opened to manage income like rent, dividend and pensions, etc., earned in India and is non-repatriable. However, RBI regulations allow repatriation up to $1 million in a financial year. Interest earned on the account is fully transferable. Income earned abroad can also be deposited in this account.

Banks charge a variety of fees like debit card fees, cheque book fees, transaction fees, convenience fees etc., from NRI customers. We are not discussing these fees in detail as these fees are related to banking services and not related to trading & investments.

NRI Trading Account Charges

An NRI Trading Account is a must for NRIs to trade in Stocks, Stock Derivatives, IPOs, Mutual Funds, and Bonds at BSE and NSE.

As per the government regulations, NRIs are only permitted to trade in equity, equity Futures & Options, and Currency Derivatives. They are not permitted to do intra-day trading or trade in Commodity in India.

An NRI Trading Account can be opened with a stock broker like Zerodha, ICICI Direct, and HDFC Securities to name a few.

NRIs need to pay the following types of charges for NRI Trading Account:

NRI Trading Account Charges & Fees

NRI Trading Account Opening Fee (One Time)

It is a one-time fee paid at the time of opening an account.

NRI Trading Brokerage Charges

The brokerage is the commissions charged by the broker for transactions like buy and sell orders. The brokerage charge varies by broker to broker. Some broker charge flat fee per order (i.e. Rs 200 per trade) while others charge a percentage of the total transaction value (i.e. 0.50%).

Platform Access Fees

Some stock brokers also charge a subscription fee from customers for accessing their advanced trading platforms and tools. The platform access fee can be charged annually or monthly.

Call & Trade Fee

Most stock brokers also charge a fee for orders placed on the phone by calling the trading desk. This fee is charged per executed order. So, if you are placing 3 orders on a call, you have to pay 3x the fee. Some brokers offer limited free orders and orders beyond that are charged.

Exchange Transaction Charges

It is fee is charged per transaction by stock exchanges. It is charged as a percentage of the trading value.

Taxes

  • Security Transaction Tax (STT) - 0.1% on both Buy and Sell
  • GST - 18% on Brokerage + Transaction Charge
  • SEBI Charges - Rs 5/Crore
  • Stamp Duty

NRI Demat Account Charges

The Demat Account holds securities like Stocks, Mutual Funds, IPO stocks and Bonds, etc. in electronic form. It works similar to a bank account but instead of money, it holds the securities.

An NRI Demat Account is a must for NRIs looking to trade in Indian stock exchanges. It is similar to a resident demat account in terms of account opening process, charges and the way it is managed.

An NRI Demat account attracts various charges. The fees include charges levied by the Central Depository, Depository Participant (Broker) and government taxes. Some key NRI demat account charges are:

NRI Demat Charges

Account Opening Fee (One Time)

Most brokers charge an account opening fee for processing the account opening application. This fee is to be paid a one-time.

Annual Maintenance Charges (Yearly)

The Demat AMC is charged by the broker for maintaining your account. It is an annual fee charged irrespective of whether you have done any transaction in your account or not.

Debit Transaction Charges

It is a fee charged when you sell shares and the shares are withdrawn from the demat account. This fee is levied for every withdrawal from your demat account. Some brokers charge a flat rate fee while other charges it as a percentage of the value of the transaction.

Other Charges

The Other changes for NRI demat account include Pledge Fees and Fee for modification/updating of your info or linked bank account.

NRI Custodial Accounts

NRI Custodial Accounts are a must for NRIs to invest in Equity Derivatives (F&O) in India. There can be an exception to this if the broker is a clearing member and the broker can clear the F&O trades for you. In such a case, you may not require to open a custodial account.

To trade in F&O, an NRI has to open an account with Custodial and get a CP code. Custodians are SEBI registered members who help the NRIs in getting the CP code and clear the F&O trades at the exchange on behalf of the NRI customers.

The funds for the F&O trading remain with the custodian. It works similarly to the funds for NRI stocks delivery trading remain with the bank and transferred to the broker once they share the contact note with bank. The funds for derivative trades are also transferred to the custodian at the end of the trading day.

All equity derivative trades of NRIs are cleared through a clearing member using the CP code. The code is also used by stock brokers to execute the F&O trades on behalf of an NRI customer. When a CP code is used, the trade obligations including payment of margin and settlement go to the Custodial.

Opening a custodial account required at least Rs 25 lakhs portfolio size including cash, stocks or any other security that you can deposit with the custodian.

NRI Custodial Account Charges

Account Opening Fee (One Time)

Custodial charge an account opening fee for processing the account opening application. This fee is to be paid a one-time.

Minimum Deposit

Most Custodial ask for Minimum Rs 25 Lakhs margin deposit with them.

Clearing Charges

Clearing charge is the fee levied by the Clearing Member (Custodial in case of NRI) for settling all derivatives trades done by the client on the exchange.

NRI Trading Charges of Top 5 NRI Stock Brokers

1. Zerodha NRI Trading Charges

NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (3)

Zerodha is India's largest stock broker. It is a discount broker popular for its excellent online trading platforms and flat-fee brokerage.

Zerodha offers 2-in-1 NRI Account consists of a trading and a demat account. Zerodha serves only those NRIs who have their PIS accounts with Axis, HDFC or Yes Bank.

Read Zerodha NRI Account Review to know in detail about Zerodha NRI Trading services.

Zerodha NRI Trading Charges

NRI Trading Account Opening Fee (One Time)

Rs 500 (Combined for trading & demat account)

NRI Trading Brokerage Fees

  • Equity Delivery Brokerage: Rs 200 per executed order
  • Equity Future Brokerage: Rs 100 per executed order
  • Equity Options Brokerage: Rs 100 per executed order

Platform Access Fees

  • Zerodha Kite(Web & Mobile): Free
  • Smallcase: Rs 100 Per transaction
  • Sensibull: Free: Rs 0 | Lite: Rs 800 | Pro: Rs 1300 Monthly
  • Streak: Basic: Rs 500 | Premium: Rs 900 | Ultimate: Rs 1400 Monthly
  • Kite Connect: Connect: Rs 2000 | Historical: Rs 2000 Monthly
  • Pi Bridge: Rs 500 Monthly

Dial-n-Trade Fee

Rs 20 per order

NRI Demat Account Opening Fee (One Time)

Rs 500 (Combined for trading & demat account)

Demat Annual Maintenance Charges (Yearly)

Rs 300

Demat Debit Transaction Charges

Rs 13.5 per scrip (irrespective of quantity)

PIS Issuance Charges

NA

PIS Account Maintenance Charge

NA

PIS Transaction or Reporting Charges

NA

2. SBI NRI Trading Charges

NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (4)

State Bank of India is the largest bank in India. SBI NRI customers can invest online in Equities, Derivatives, IPOs, and Mutual Funds through its 4-in-1 account consisting of trading, demat, bank and PIS accounts.

Read SBI NRI Account Review to know in detail about SBI NRI Trading services.

SBI NRI Trading Account Charges

NRI Trading Account Opening Fee (One Time)

Rs 500

NRI Trading Brokerage Fees

Equity Delivery Brokerage: 0.75%

Platform Access Fees

Zero

Call & Trade Fee

30 calls free in a month after which Rs.10 will be charged per call

NRI Demat Account Opening Fee (One Time)

Rs 2500

Demat Annual Maintenance Charges (Yearly)

Rs 750

Demat Debit Transaction Charges

0.50 %

PIS Issuance Charges

Rs 750

PIS Account Maintenance Charge

  • For 1st year of operations: Nil
  • 1st year onwards: Rs 1000

PIS Transaction or Reporting Charges

3. HDFC NRI Trading Charges

NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (5)

HDFC offers a range of trading and investment services to NRIs. HDFC offers NRI 3-in-1 accounts which combine banking, broking and demat account.

Read HDFC NRI Account Review to know in detail NRI Trading services offered by HDFC.

HDFC NRI Trading Account Charges

NRI Trading Account Opening Fee (One Time)

Rs 2500

NRI Trading Brokerage Fees

  • Equity Delivery Brokerage: 0.75%
  • Equity Future Brokerage: 0.025% (Both Buy & Sell)
  • Equity Options Brokerage: Rs 100 per lot

Platform Access Fees

  • Web & Mobile Trading App: Free
  • ProTerminal: Rs 2,499 Yearly.
  • Blink: Rs 3,999 Yearly

Call & Trade Fee

Free

NRI Demat Account Opening Fee (One Time)

Zero

Demat Annual Maintenance Charges (Yearly)

First Year- Free, Rs 750 from next years

Demat Debit Transaction Charges

0.04% of the value of the transactions.

PIS Issuance Charges

Rs 1000

PIS Account Maintenance Charge

Rs 1000

PIS Transaction or Reporting Charges

Rs 100 per contract

4. ICICI NRI Trading Account Charges

NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (6)

ICICI Direct offers a unique 3-in-1 account integrating banking, trading and demat accounts. The account facilitates trading in a range of options including Stocks, Equity Derivatives (F&O Trading), Mutual Funds, and IPOs. In addition, ICICI also offer services related to PAN Card and Portfolio Investment Scheme (PIS) etc

Read ICICI Securities NRI Account Review to know in detail about ICICI NRI Trading services.

ICICI NRI Trading Account Charges

NRI Trading Account Opening Fee (One Time)

  • UK Clients: Rs 6500
  • Non-UK Clients- Rs 4000

NRI Trading Brokerage Fees

  • Trades above Rs 50 lacs: 0.50 %
  • Rs 25 lacs to Rs 50 lacs: 0.75 %
  • Rs 10 lacs to Rs 25 lacs: 0.90 %
  • Rs 5 lacs to Rs 10 lacs: 1.00 %
  • Up to Rs 5 lacs: 1.25 %

Platform Access Fees

Zero

Call-n-Trade Fee

20 Calls Free Per Month. Rs 25 every additional call.

NRI Demat Account Opening Fee (One Time)

Combined with Trading Account Opening Fees.

Demat Annual Maintenance Charges (Yearly)

  • For overseas correspondence address: Rs 1200
  • For Indian correspondence address: Rs 500

Demat Debit Transaction Charges

PIS Issuance Charges

PIS Account Maintenance Charge

AMC for the first year is waived off for the PINS accounts opened along with ICICIdirect. Rs 2500 charged from next year.

PIS Transaction or Reporting Charges

5. Axis Bank NRI Trading Account Charges

NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (7)

Axis bank offers a 4 in 1 NRI Account which facilitates online investments in equities, derivatives, IPOs, mutual funds and ETFs. Axis Bank offers a range of services to NRIs including PIS, Banking and Investments etc.

Read Axis Bank NRI Account Review to know in detail about various Axis NRI Trading services.

Axis Bank NRI Trading Account Charges

NRI Trading Account Opening Fee (One Time)

Rs 2500

NRI Trading Brokerage Fees

Equity Delivery Brokerage: 0.75%

Equity Future Brokerage: 0.05%

Equity Options Brokerage: Intraday: 1p per lot, Carry Forward: Rs 10 per lot

Platform Access Fees

Zero

Call-n-Trade Fee

5 calls in a calendar month are free. Additional calls will be charged Rs 20 per call.

NRI Demat Account Opening Fee (One Time)

Demat Annual Maintenance Charges (Yearly)

First Year - No AMC

Second Year Onwards: Rs 750

Demat Debit Transaction Charges

0.04% of the value of the transaction or Rs 25 (per Instruction) whichever is higher.

PIS Issuance Charges

Rs 1000

PIS Account Maintenance Charge

Rs 1500

PIS Transaction or Reporting Charges

Rs 150 per trade

NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (8)

  1. 1. What is the process to close an NRE/NRO account?

    An NRE or NRO account can be closed by submitting a closure request form to the bank or by filling up a redesignation form to convert the existing NRE/NRO account to a resident savings account or Resident Foreign Currency account.

    An NRI may want to close an existing NRE/NRO account under below 2 scenarios:

    1. To open NRE/NRO accounts in another bank
    2. On return back to India.

    Steps to close the NRE/NRO account:

    1. Download the Account closure form from the bank website.
    2. Fill up the entire form and sign it.
    3. Send the form to the bank for processing. [ You may also require to send the unused cheque leaves along with the closure form]

    For NRIs returning to India, you are required to inform the bank about the change of your residency status. The bank may ask for a declaration in writing or ask to fill up a form for the redesignation of accounts. The existing NRE/NRO account can be redesignated to a resident savings account or the NRI also has an option to convert the existing NRE account to Resident Foreign Currency Account wherein an NRI can maintain funds in foreign currency with full repatriation benefits. This may help an NRI in case his residency status changes back to NRI and the funds in the RFC account can be easily transferred to any NRE account without any issues.

    It is important to note that the process of each bank may vary a bit. Some banks may require an in-person visit to the bank for the closure process. Some banks may close the existing bank accounts and open a new savings account while some may redesignate the same accounts to resident accounts. Thus, it would be best to approach your bank for guidance to know the exact process followed at their end.

    Discuss this question

  2. 2. Can an NRI trade in his father's trading account?

    An NRI can trade using his father's trading account. However, the father would be liable to pay income tax on any gains arising from such investments.

    An NRI can transfer money to the father's bank account as a gift or loan which would be linked to the trading and Demat account. Due to online trading facilities made available by almost all brokers, an NRI can easily operate and manage father's trading and Demat accounts and trade without any complexities of getting involved in NRI Trading account opening and handling.

    Important Points to Note:

    • An NRI cannot link his bank account to the father's trading account. The bank account, Demat account, and trading account should all be in the same name.
    • Though the above approach can be used as a workaround, it is not advisable to do so to avoid any issues in the future on account of any investigations. It is always recommended to trade in the capacity of an NRI, on attaining the residency status of NRI.

    Discuss this question

  3. 3. How to open NRI trading account?

    An NRI trading account can be opened by approaching a stockbroker or banks offering 3-in-1 account services. An NRI trading account is required to place the buy/sell order with the broker.

    Documents required for opening an NRI trading account:

    1. Document about your current Status:
    • In case of an Indian passport:
      • Valid passport and
      • Place of birth as India and
      • Valid Visa - Work/Student/employment/resident permit etc.
    • In case of foreign passport: Valid passport and any of the following:
    • Place of Birth as India in the foreign passport or
    • Copy of PIO / OCI Card
    1. Copy of the PIS Permission Letter from the respective designated bank for trading on a repatriation
    2. Copy of FEMA declaration.
    3. FATCA declaration.
    4. The PIS NRE/NRO bank accounts cancelled check leaf.
    5. PAN Card.
    6. Overseas Address Proof - Driving License/ Foreign Passport /Utility Bills/Bank statement (not more than 2 months old)/Notarized copy of rent agreement/ leave & license agreement/ Sale deed.
    7. Proof of respective bank accounts & depository accounts.
    8. Account opening fee cheque.
    9. Duly signed account opening forms.

    Note:

    1. The above is a generic list of documents for reference and the requirements may vary a bit from broker to broker.
    2. The documents should be self-attested and notarized by Indian Embassy or any other competent authority like Consulate General / Notary Public / Any Court / Magistrate / Judge / Local Banker in the country where the NRI resides.

    Discuss this question

  4. 4. Can NRI do day trading?

    Day trading is the same as intraday trading and an NRI is not permitted to do day trading.

    An NRI can invest and trade only on a delivery basis i.e. an NRI is required to take the delivery of stock on T+2, T being the trading day. Only once the stock is credited to the Demat account, an NRI can place the sell order. An NRI cannot do short selling.

    Discuss this question

  5. 5. Can NRI use Demat account in India?

    An NRI can use a Demat account in India just like resident Indians to hold the securities in electronic format. A Demat account is one of the mandatory requirements for an NRI to invest in the stock market.

    An NRI is required to open a repatriable Demat account(NRE) or a non-repatriable Demat account (NRO) depending on whether an NRI is investing on repatriation or non-repatriation basis respectively.

    The Demat account is required to hold:

    1. The stocks purchased through the stock exchange in the capacity of an NRI;
    2. The shares bought in the capacity of a resident Indian;
    3. The shares applied in IPO;
    4. Bonus shares;
    5. Rights Issue; and
    6. Shares received as a gift.

    Discuss this question

More articles in this category...List of all Articles

  1. NRE vs NRO Bank Account in India for NRI
  2. NRI Trading in Derivatives (Futures and Options Trading) in India
  3. NRI Demat Account - Online Opening Procedure, Charges, Rules
  4. NRI Mutual Fund Investment Online in India
  5. NRI Trading Step by Step Guide
  6. USA NRI Trading Account in India
  7. NRI Trading in Currency Derivatives
  8. NRI Investment in Govt Securities (G-secs, Treasury Bills)
  9. NRI Trading Requirements (Accounts for trading in India)
  10. NRI Taxation in India (Stocks, Mutual Funds and Derivatives)
NRI Trading Charges Explained (Brokerage, AMC, PIS, Demat) (2024)

FAQs

What is PIS AMC charges? ›

PIS approval issuance fee ( one time fee) Rs.1000.00. 2. Annual account maintenance fee. Rs.1000.00.

What are the charges for NRI trading account? ›

Trading and Demat Account Opening Charges
ParticularsAmount
Trading account opening charges (One Time)₹36.48
Demat account opening₹450+ ₹50 – POA+applicable GST and education cess, approx comes to ₹500

What are the Demat account brokerage charges for SBI NRI? ›

5. What are SBI NRI demat account brokerage charges? SBI charge flat 0.75% of the transaction value as brokerage charge for all executed trades at BSE and NSE by the NRIs. Note that unlike discount brokers like Zerodha and ProStocks, SBI doesn't offer flat rate brokerage.

What is AMC for Demat account charges? ›

Demat Account Annual Maintenance Charges

The Brokerage Houses and Depository Participant (DPS) levy a minimal annual maintenance fee or the folio maintenance fee for their services. The AMC fee amount is generally between INR 300 to INR 900. You can pay the fee as a one-time payment or quarterly.

Is PIS mandatory for NRI? ›

Yes, It is mandatory for a NRI to route all secondary market transactions through his PIS designated account i.e For all purchase / sell of stocks in secondary market only the PIS designated account should be debited / credited.

How can I avoid AMC charges? ›

Choose AMC Free Card

The most effective way to avoid ATM card AMC is to choose a bank that offers payment cards without any annual maintenance charge. For example, some banks offer low to zero AMC for basic ATM cards, while others offer higher AMC for high-facility debit cards.

What is the charge of PIS in Zerodha NRI? ›

PIS: 0.5% or ₹200, whichever is lower per executed order. Non-PIS: 0.5% or ₹100, whichever is lower per executed order. ₹100 per executed order. Futures: ₹150 per crore charged monthly.

Which is the lowest brokerage charges for NRI in India? ›

Zerodha and Prostocks are the two best NRI discount brokers in India. Prostock is the low-cost NRI trading broker that charges Rs. 100 flat brokerage on NRI trading while Zerodha charges Max Rs. 200 per order brokerage.

Can NRI have 2 trading accounts? ›

Yes, clients can have two separate trading accounts based on NRE & NRO.

Which broker is best for NRI? ›

Best Stock Broker for NRI in India
RankBrokerRequest Callback
ProStocksOpen Online Account
1ZerodhaOpen Account
2Angel OneOpen Account
3ICICIdirectOpen Account
7 more rows

Can NRI have 2 demat accounts in India? ›

An NRI, at any point in time, can hold multiple demat accounts under their name. In fact, if you're a regular investor, you can choose to open all the above three NRI demat accounts - one for repatriable investments, another for non-repatriable investments, and a third for investing in the secondary market.

What is the difference between PIS and non PIS account? ›

PIS and Non-PIS are two different types of accounts that you can use to invest in the Indian stock market. PIS is suitable if you want to invest your foreign earnings in India. However, it has some limitations, such as higher fees, lower flexibility, and restricted transactions.

Which broker has zero AMC charges? ›

List of stock brokers offering Zero Demat AMC Accounts for Lifetime
BrokerDeliveryDemat AMC
Upstox2.5% or Rs 20 whichever is lowerFree
ProStocksFreeRs 0 (Rs 1000 Refundable Deposit)
Paytm Money2.5% or Rs 20 whichever is lowerFree
Groww0.05% or Rs 20 whichever is lowerFree
1 more row

How do you calculate AMC charges? ›

What is Account Maintenance Charge (AMC)?
Holding valueAnnual chargesQuarterly charges
Up to ₹50,000Zero chargesZero charges
₹50,001 to ₹2,00,000₹100 + 18% GST₹25 + 18% GST
Above ₹2,00,000₹300 + 18% GST₹75 + 18% GST

What is AMC charges for SBI? ›

The AMC (annual maintenance charges) for this debit cum ATM card is Rs.125 plus GST. The applicable charges for this debit card are Rs.125 plus GST. The annual maintenance charge for this debit card is Rs.175 plus GST. The applicable AMC for a Platinum Debit Card is Rs.250 plus GST.

What is PIS scheme for NRI? ›

So What is PIS Account? According to Schedule 3 of the Foreign Exchange Management Act 2000, NRIs can purchase and sell shares as well as convertible debentures of companies registered in India via a recognised stock exchange, by routing these transactions through their account with a designated bank branch.

What is the meaning of PIS account? ›

For Investment in Secondary Market by Non-Resident Indians

The Portfolio Investment Scheme (PIS) allows NRIs to invest in shares of Indian companies, in secondary market, under repatriation or non-repatriation basis through a registered stock broker on a recognized stock exchange.

What is the use of PIS account? ›

Portfolio Investment Scheme (PIS) Account allows NRIs to invest in shares of Indian companies under repatriation or non-repatriation basis.

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