No, and that is the point of it. India's international financial services centre operates on a different tax and regulatory basis from the rest of India, so for planning purposes it behaves as a distinct jurisdiction. Units established there can access specified exemptions and concessions, but each is subject to conditions, and the conditions are where the analysis lives. Before treating the centre as a low-tax location, establish which concession you are actually relying on, what it requires, and how long it is available for. A general description of the regime is not a basis for a structure.
GIFT City & IFSC structures — what should I check first?
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Units established there access specified exemptions and concessions subject to conditions, and fund and treasury structures are the common use cases. One question decides whether this is a filing or a project.
What to check first
Units established there access specified exemptions and concessions subject to conditions, and fund and treasury structures are the common use cases. Eligibility, permitted activities and the sunset of particular concessions decide whether it fits.

Where it does not apply
India's international financial services centre operates on a different tax and regulatory basis from the rest of India, which makes it a distinct jurisdiction for planning purposes.
Where to go from here
The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on GIFT City & IFSC structures. Ask before the move rather than after it, because most of the useful options expire on the date.
Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.
Files that look like this one
Fund structure compared against an alternative outside India
A manager raising from investors across several countries asked whether to establish the vehicle in the international financial services centre or elsewhere. The work set the two side by side on the things that decide it: which exemptions and concessions a unit could access, the conditions each carries, the permitted activities, and the ongoing cost of maintaining eligibility. We also mapped what each option would mean for investors in their own countries. The engagement produced a written comparison with the conditions attaching to each relief, and a recommendation the manager could show to prospective investors.
Read how this one runsPermitted activity tested before any unit was established
A group intending to run part of its business from the centre described an activity that did not clearly sit within the permitted list. Rather than establish first and ask later, we tested the intended business against what a unit is permitted to undertake, and against the eligibility conditions of the particular relief the group wanted. Part of the activity fitted; part did not. The engagement produced a written eligibility analysis, a revised description of what the unit would carry on, and a note of the functions that would have to remain outside it.
Read how this one runsConcession timing decided whether the structure went ahead
A structure had been designed around a concession whose availability period was approaching its end. The review asked one question in writing: what does this structure look like once that relief is no longer available? We worked through the remaining reliefs, the conditions each carries, and the cost of establishing and running the unit over the period that would remain. The engagement produced a timing analysis and a documented decision not to proceed on the original design, together with the alternative the group adopted instead.
Read how this one runsTreasury unit reviewed for eligibility and its running conditions
A group treasury function was proposed for the centre on the basis of a general description of the regime. We replaced that with specifics: which concession the group would rely on, the conditions attaching to it, the activities the unit would be permitted to carry on, and the substance the group would have to put behind it. The engagement produced an eligibility file, an operating description of the treasury activity written so that it matches what the unit would actually do, and a list of the annual conditions somebody has to own.
Read how this one runsInvestor reporting at home mapped alongside the Indian treatment
An investor holding an interest in a fund established in the centre had good Indian advice and none at home. We mapped the home-country treatment of the interest, the information reporting it triggers, and the interaction between the Indian concessions and the way the home country taxes the same income. The engagement produced a written note of the reporting obligations by year, a position on the character of the income at home, and a corrected set of information returns for the periods that had been missed.
Read how this one runsExisting Indian operations reviewed for a move into the centre
A company already operating in India asked about moving activities into the centre. The review separated three questions: whether the intended activity is permitted for a unit, whether the group met the eligibility conditions of the relief it wanted, and what the transfer itself would cost under ordinary Indian rules. Because the centre operates on a different basis from the rest of the country, the move was treated as establishing a new proposition rather than changing an address. The engagement produced a step plan, an eligibility analysis, and a costed comparison with staying put.
Read how this one runsA Company Abroad Owned by a US Person
A business incorporated where the owner lives is a foreign corporation to the IRS, with a reporting package of its own and schedules that need local accounts restated. Classification comes first, because it decides what is reportable and when profits are taxed.
Read how this one runsA Country-by-Country Report and Who Files It
The obligation sits with the group and the filing can fall on a surrogate where the parent's jurisdiction does not exchange. Establishing who files where comes before preparing anything.
Read how this one runsAll case studies — every published engagement in one place.
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Also asked about GIFT City & IFSC structures
Permitted activities are defined, and the common use cases are fund and treasury structures. An entity cannot simply carry on whatever business it likes from within the centre and expect the concessions to follow. So the first check is a match between the business you intend to run and the activities a unit is permitted to undertake, followed by the eligibility conditions attaching to the particular relief you want. Where the intended business only partly fits, the realistic options are to restructure the activity or to accept that part of it sits outside the regime.
Not necessarily. Particular concessions have their own availability periods, and the sunset of one of them can change the arithmetic of a structure that was built around it. That makes timing part of the decision rather than a detail. A unit set up to capture a relief that is closing may not repay the cost of establishing and running it. Check which relief you are relying on, what conditions it carries and how long it runs, before committing to the structure rather than after the unit exists.
It depends on whether the concessions you would actually use outweigh the cost of eligibility. A unit has to be established, it has to carry on a permitted activity, and it has to meet the conditions of each relief it claims, all of which carry running cost. Fund and treasury structures are the common use cases because those are the businesses where the reliefs bite hardest. For a smaller vehicle the honest test is to price the compliance first and compare it with the benefit, rather than the other way round.
Treat it as establishing a unit rather than relocating an address. A unit there is a separate proposition with its own eligibility conditions and its own permitted activities, and none of that follows from the company already existing in India. Moving an existing business in raises questions about what transfers, what stays behind, and how the transfer itself is taxed under ordinary Indian rules. Work the eligibility and permitted-activity questions first. If the business does not fit, the transfer analysis never becomes relevant.
Almost certainly. A holding or an interest in a fund or treasury vehicle in the centre is a foreign interest from the perspective of the country you are resident in, and that country applies its own rules to it regardless of how the income is treated in India. Information reporting is the part people miss, because the concession being relied on sits in one country while the reporting obligation sits in another. Map the home-country consequences alongside the Indian ones before the structure is fixed.
Yes, through more than one channel. The treaty has an exchange-of-information article that supports both routine and on-request exchange. Separately, an intergovernmental agreement has Canadian financial institutions identify US-reportable accounts and report them to the CRA, which passes them to the IRS, with the reverse flow for Canadian residents. Most other country pairs use the Common Reporting Standard for the same purpose. See FATCA reporting.
Cross-border tax is what applies when income, assets or people touch more than one tax system at once — someone living in one country and earning in another, a company selling or hiring abroad, a family holding property in a second country. The work is rarely one country's rules applied harder; it is reconciling two sets of rules and claiming the relief that stops the same income being taxed twice at full rates. See what we do.



