If you want concentrated exposure to US mega-caps from India, there is more than one way to do it. You can buy an Indian fund of fund in rupees, buy the underlying ETF listed on the NSE, or remit money abroad under LRS and buy a UCITS ETF directly.
No UCITS ETF tracks the S&P 500 Top 50 Index, the 50 largest US companies by free-float market cap, which the Mirae Asset S&P 500 Top 50 ETF Fund of Fund uses. So this piece compares three real options: the NSE-listed Mirae Asset S&P 500 Top 50 ETF, the Fund of Fund that invests in it, and the closest legitimate alternatives available through UCITS.
The NSE-listed ETF holds the 50 stocks directly and trades on the exchange like a stock. It was launched in September 2021, has a 0.60% expense ratio and roughly Rs 1,100 Cr in AUM, and requires a demat and trading account rather than a mutual fund folio.
The Fund of Fund invests in this same ETF, wrapping it in a mutual fund structure. It is bought in rupees with a minimum investment of Rs 5,000, requires no demat account, and gives the same concentrated exposure to the largest US companies across every sector, at a higher stacked cost.
The closest UCITS alternative is the iShares Core S&P 500 UCITS ETF (CSPX), which holds the full 500-stock S&P 500 rather than just the top 50. There is also a narrower option, the iShares S&P 500 Top 20 UCITS ETF, with a 0.20% TER and about €493 million in AUM, launched in November 2024, which tracks a different 20-stock capped-weight index and is newer and smaller than CSPX. Neither is an exact match.
Table of contents
- The NSE-listed ETF: the direct rupee route
- What the Fund of Fund adds
- Why there is no UCITS equivalent
- Cost comparison
- Performance: how each fund tracks its index
- Why does the fund keep restricting subscriptions?
- Already hold the FoF? What switching involves
- Taxation in India
- Ownership and portability
- Which route is right for you?
- Switching to Paasa
The NSE-listed ETF: the direct rupee route
The NSE-listed Mirae Asset S&P 500 Top 50 ETF holds the 50 stocks directly and trades on the exchange like a stock. It has a 0.60% expense ratio, stays entirely in rupees, and needs a demat and trading account rather than a mutual fund folio.
You can buy this at the market price rather than end-of-day NAV, and there is a bid-ask spread to account for. If you already have a demat account and are comfortable placing trades, this ETF is the lowest-cost way to get this exact exposure without going anywhere near UCITS or LRS.
What the Fund of Fund adds
- The same exposure, no demat account. The FoF invests in the ETF above, so you get the same concentrated mega-cap exposure through a mutual fund folio, with SIP and lumpsum options on any mutual fund platform.
- A stacked cost. You pay the FoF's own charge on top of the ETF's expense ratio inside it, so it costs more than buying the ETF directly.
- No US estate tax exposure. Like the ETF, the FoF is an Indian mutual fund and never holds US-listed securities in your name.
Why there is no UCITS equivalent
No UCITS ETF tracks the S&P 500 Top 50 Index. The nearest thing, the iShares S&P 500 Top 20 UCITS ETF, tracks a different, capped-weight 20-stock index. It launched in November 2024 and has a fraction of CSPX's scale and track record.
So the real question is not which fund tracks the same thing more cheaply. It is whether the concentration you get from the Mirae Asset FoF is worth the trade-off: give up scale and track record for the Top 20 UCITS fund, or give up concentration for CSPX and its full 500 stocks and lower cost.
The structural difference: direct ETF vs two-layer FoF vs UCITS
The NSE-listed ETF holds the stocks directly. You buy it on the exchange, in rupees, and you never deal with foreign exchange or LRS.
The Mirae Asset FoF is a fund that buys another fund. Your money goes into the FoF, the FoF buys units of the NSE-listed ETF, and the ETF buys the stocks. You still hold everything in rupees with no LRS involved, but you are paying for two layers instead of one.
CSPX (or the Top 20 UCITS fund) 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 is what drives the cost comparison below: one layer in rupees, two layers in rupees, or one layer in dollars.
Cost comparison
The FoF's disclosed expense ratio looks cheap, but it is only one of two layers: the FoF's own charge, plus the underlying Mirae Asset ETF's expense ratio inside it. The NSE-listed ETF has only one layer, since you would hold it directly.
| Cost item | Mirae Asset FoF | NSE-listed ETF (MASPTOP50) | CSPX (full S&P 500) |
| Expense ratio | ~0.6%–1.3% total, depending on plan and layer | 0.60% | 0.07% TER |
| Exit load | 0.5% if redeemed within 3 months | None (brokerage charges apply per trade) | None |
| Access needed | Mutual fund folio only | Demat and trading account | Demat/brokerage account abroad via LRS |
| Currency | Rupees | Rupees | US dollars |
| One-time costs | None | Brokerage per trade, bid-ask spread | Remittance and FX conversion charges, brokerage |
Note: the FoF's reported expense ratios vary noticeably across sources and dates, roughly 0.6% to 1.3% depending on plan. Check the current figures on the latest factsheet before you invest, since the range above is indicative rather than exact.
CSPX's 0.07% is all-in, since it holds the underlying stocks directly.
Performance: how each fund tracks its index
The Mirae Asset ETF and FoF track the S&P 500 Top 50 Index, a different benchmark from the plain S&P 500, so their returns cannot be compared directly to CSPX's returns even after adjusting for currency.
What can be compared fairly is cost drag and tracking discipline within each vehicle.
The FoF's tracking gap against its own benchmark comes from the two-layer expense stack plus any cash buffer held for liquidity.
CSPX has actually outperformed its full S&P 500 benchmark every calendar year from 2016 to 2025, by roughly 0.2 to 0.3 percentage points annually, helped by securities lending income and Ireland's lower withholding tax rate on US dividends.
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.
Mirae Asset's overseas schemes, including this one, were suspended from February 2022 alongside the rest of the industry. The Mirae Asset S&P 500 Top 50 ETF FoF reopened in March 2023 with no upper limit on lumpsum, switch-in, or SIP investments, unlike some other AMCs' funds that reopened with a capped amount per month.
Mirae Asset did re-suspend a few of its other, newer overseas thematic FoFs again in 2024, but this fund does not appear to have been included in that restriction.
What this means for you in practice:
- Confirm this fund's current subscription status before investing, since overseas fund restrictions can return with little warning industry-wide.
- Whether fresh investment stays open depends on the industry's overall headroom under the USD 7 billion cap, which you cannot predict or control.
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 FoF? What switching involves
If you already hold the FoF, switching is a decision to make deliberately, not in a rush. Three things to know:
1. Redeeming triggers capital gains. Selling your FoF 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. A 0.5% exit load applies within 3 months. This is longer than the 7-day windows on some other Indian index funds. Check your allotment date before redeeming.
Taxation in India
For Indian residents, the tax treatment of the FoF and any UCITS route is close.
| Mirae Asset FoF | Mirae Asset ETF | UCITS ETF | |
| Long-term holding period | 24 months | 24 months | 24 months |
| LTCG rate | 12.5% | 12.5% | 12.5% |
| STCG rate | Slab rate | Slab rate | Slab rate |
| Schedule FA disclosure | Not required | Not required | Required every year you hold |
| TCS on investment | None | None | 20% on LRS remittances above Rs 10 lakh per year, adjustable against tax |
The 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.
A UCITS ETF is held in a global brokerage account in your name. If you move from India to Dubai, Singapore, or London, the holding moves with you.
US-based NRIs should note that UCITS funds face their own PFIC treatment once you become a US person, so this portability advantage does not extend to a move to the US specifically.
Which route is right for you?
The Mirae Asset FoF route fits you if:
- You specifically want concentration in the top 50 companies, not the full S&P 500 or top 20
- You invest in rupees via SIP and don't want a demat account involved
- You are comfortable that the S&P 500 Top 50 Index has a shorter track record and fewer comparable funds than the plain S&P 500 does
The NSE-listed ETF fits you if:
- You want the same mega-cap concentration as the FoF, at a lower cost
- You already have a demat and trading account and are comfortable with market-price execution instead of NAV
- You want to stay in rupees without going near LRS
The UCITS route fits you if:
- You are fine with the full 500-stock S&P 500 instead of a top-50 slice
- You are investing a meaningful corpus where the cost gap compounds significantly
- There is any chance you will live outside India
Since there is no exact UCITS match, this decision is less about switching between equivalents. It is about deciding whether mega-cap concentration is worth the extra cost of the FoF, or whether the full S&P 500 through CSPX serves the same underlying goal for far less.
Switching to Paasa
If you have decided to move your US equity exposure from the Mirae Asset 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.
- Compliance advantage: Get Schedule FA reports and Indian capital gains statements generated for you at tax time.
