Foreign portfolio investors (FPIs) looking for concessions to convert themselves into companies from a trust structure in order to avoid paying a higher surcharge may have to wait until the next budget. The government will have to amend a host of provisions in the income tax to make such conversions tax-neutral. The government had raised the surcharge to 25% from 15% for people with taxable incomes between Rs 2-5 crore, and to 37% for those earning over Rs 5 crore. This covers FPIs that are structured as trusts and associations of persons (AoPs). Those structured as corporates are exempt.