A corporate treasury centre in GIFT City is a finance company, or a branch called a Finance Unit, registered with IFSCA to carry on the activity of a “Global/Regional Corporate Treasury Centre” (GRCTC). The rules are in IFSCA’s GRCTC Framework of 4 April 2025: a company or branch, a minimum owned fund of USD 0.2 million, at least five qualified staff in the IFSC (which the Chairperson may relax for up to a year), and services to group entities in India and abroad. Indian group companies can be served, but each flow with them must work under FEMA.

“Framework” below means the Framework for Finance Company / Finance Unit undertaking the activity of Global / Regional Corporate Treasury Centres (F. No. IFSCA/24/2024-Banking-FC/01, 4 April 2025). “FC Regulations” means the IFSCA (Finance Company) Regulations, 2021, as amended up to 7 May 2026. For how a treasury centre compares with other IFSC licences, see Setting Up in GIFT City: Entity Types and IFSCA Licences.

Table of Contents

The legal basis of a GIFT City treasury centre

The FC Regulations list “Global/Regional Corporate Treasury Centres” as a core activity of a finance company (reg. 5(1)(ii)(e)). The Framework operationalises it. It came into force on issue (cl. 1(2)) and repealed the circular of 25 June 2021 (cl. 19(1)). GRCTCs registered under the old circular had six months to meet the new requirements (cl. 19(3)).

A circular of 9 June 2025 (F. No. IFSCA/24/2024-Banking-FC/02), in force immediately, added a proviso to the staffing condition in cl. 3(2)(ii): “based on a request made by the Applicant, the Chairperson of the Authority may grant relaxation from the above condition, considering the permissible activities proposed to be undertaken and the proposed business volume, for a period not exceeding one year from the date of commencement of operations.” It names no lower headcount. IFSCA’s GRCTC page lists only the 4 April 2025 Framework, so the proviso is read here from the circular itself.

Who can set up a corporate treasury centre

The applicant must, when it applies (cl. 3(2)):

have or undertake to set up office space, equipment and communications in the IFSC;
undertake to employ “at least five (5) qualified personnel, based in IFSC”, including the Head of Treasury and the Compliance Officer, before starting operations;
show it can meet the owned fund requirement;
have a Parent from a jurisdiction not identified by FATF as “High Risk Jurisdiction – subject to call for action”;
with its key managerial personnel and controllers, meet the fit and proper criteria in Annex I; and
not have been refused registration by IFSCA in the previous year.

“Parent” is the group entity (or entities) setting up the finance company, or the entity setting up the branch (cl. 2(1)(g)). The Framework sets no net worth, turnover or rating threshold for the group. It does not limit GRCTCs to foreign groups. An Indian group can use it.

Legal form. The applicant must be “a company or a branch of a company incorporated in India or outside India” (cl. 5). An LLP is not an option. The FC Regulations allow LLPs and trusts only for non-core activities (reg. 3(4) proviso), and treasury is core.

The branch route for a non-financial parent. Reg. 3(3) of the FC Regulations lets a Finance Unit carry on core activities only if the parent “is engaged in the business of financial services and is regulated by a financial sector regulator” at home, with a home regulator NOC “wherever applicable”. A second proviso (inserted on 1 July 2022 and present in the 2026 consolidation) disapplies that condition: it “shall not apply to an incorporated entity which desires to set up a Global/Regional Corporate Treasury Centre as a Finance Unit in the IFSCs for undertaking treasury activities or treasury services in accordance with the relevant regulatory framework specified by the Authority”. A group that is not a financial-services firm can therefore use the branch route.

	Finance Company (subsidiary)	Finance Unit (branch)
Owned fund	USD 0.2m, held in the IFSC entity	USD 0.2m, “may be maintained at the parent level” (cl. 6 proviso)
Separate legal entity	Yes	No; part of the parent
Name reservation and incorporation steps	Yes	Not needed (SWIT workflow, steps 1.b, 3)
Change of control	20% or more needs IFSCA’s prior approval (cl. 15(5))	Parent-level changes intimated within 15 days (cl. 15(5) proviso)
Financial-services parent	No such condition in the Framework	Not required for a GRCTC (reg. 3(3), second proviso, FC Regulations)

Minimum owned fund: USD 0.2 million

A GRCTC “shall have and maintain a minimum owned fund of USD 0.2 million at all times” (cl. 6). The FC Regulations’ Schedule says the same: “Higher of USD 0.2 million” or any amount under the relevant framework (item 3). That is well below the USD 3 million for other core activities. Item 2, which sets USD 3 million, expressly excludes GRCTCs.

Owned fund means paid-up capital, free reserves, share premium and certain capital reserves, less accumulated losses, intangibles and deferred revenue expenditure (cl. 2(1)(f)). Item 3 of the Schedule to the FC Regulations (not the Framework) also exempts a GRCTC from regulation 4, subject to “a Board approved prudential policy” and fit and proper criteria. Regulation 4 covers capital adequacy, the liquidity coverage ratio and the 25% ceiling on exposure to a single counterparty.

IFSCA has older finance-company circulars on prudential rules, regulatory capital, exposure ceilings and liquidity risk (2021); their application to a GRCTC is not covered here. IFSCA’s FAQs on finance companies (June 2024) also say a GRCTC is exempt from the prudential regulations on those conditions.

Staff, governance and commencement

People. Five qualified IFSC-based staff, including the Head of Treasury and Compliance Officer (cl. 3(2)(ii)). The Framework names no other key roles. The 9 June 2025 proviso allows a relaxation of up to one year from commencement.
Fit and proper. The applicant, its KMP and its controllers must meet Annex I “at all times” (cl. 7).
Board policies. Corporate governance, risk management, and a policy for permissible activities with delegations, financial limits and oversight (cl. 15(1)–(3)).
AML/CFT. IFSCA’s AML, CFT and KYC Guidelines, 2022 apply to the extent applicable (cl. 17).
Start date. Operations must start within six months of registration. IFSCA may extend by up to three months (cl. 14(1), (4)).
SEZ approval. The GRCTC must keep a valid SEZ Letter of Approval while it does business (cl. 9(3)).

What a GRCTC can do

Clause 13(1) and Annex II permit:

Activity	Key condition
Equity raising; borrowing, including inter-company deposits	Terms may be set by the GRCTC or with the service recipient (Annex II, row 1)
Credit arrangements	Includes lending, guarantees and performance bonds (row 2)
Investing in financial instruments in or outside IFSC	“Financial instruments” as in Ind AS 32 (row 3)
OTC and exchange-traded derivatives	For hedging its own or recipients’ books, or “to take positions”; Board policy required (row 4)
Foreign exchange	In currencies IFSCA specifies (cl. 13(1)(f))
Factoring and forfaiting	Separate registration under the Factors Regulations 2024 (row 5)
Re-invoicing	No physical possession of goods; a service recipient must be party to each transaction (row 6)
Liquidity management, including pooling and netting	The header or master account “must be maintained with an IBU or IBC” (row 7)
Counterparty relationships, insurance and pension obligations, advisory	Advisory linked to the listed activities (cl. 13(1)(j)–(l))
Acting as a holding company	Holding equity, bonds or loans of group entities (cl. 2(1)(e), 13(1)(m))

The registration covers the Annex II activities. A group should map the activities it will actually carry on before choosing this licence; a narrower set may sit under another IFSCA framework. The pooling rule makes the choice of IFSC bank part of the design. See IFSC Banking Units in GIFT City.

Service recipients, including Indian group companies

A GRCTC may serve its Group Entities, the Group Entities of its Parent, and their branches. These “may either be a person resident in India or a person resident outside India” under FEMA (cl. 12(1)). Group Entities cover parent-subsidiary, joint venture, associate and related-party links, a common brand name, or a 20% equity holding (cl. 2(1)(d)). Each recipient must be registered with a competent body at home (cl. 12(3)). The applicant lists its recipients when it applies and keeps the list current (cl. 4(2), 12(2)).

The Framework sets no cap on business with Indian residents. Its only condition is that dealings with them “shall comply with the provisions of the Foreign Exchange Management Act, 1999, as applicable” (cl. 12, Explanation). That is where the real limits sit.

Currencies and bank accounts

Inside the IFSC, the GRCTC transacts in specified foreign currencies (cl. 16(1)). These are the 15 currencies in the First Schedule to the IFSCA (Banking) Regulations 2020, as amended in July 2024. A transaction denominated in another currency but settled in a specified foreign currency counts (cl. 16, Explanation). Outside the IFSC, it may use other currencies (cl. 16(2)).

It may open an SNRR account with an onshore authorised dealer for business outside the IFSC (cl. 16(3)). Under an IFSCA circular of 19 June 2026, business receipts in that account must be moved to the unit’s IBU account in a specified foreign currency within 30 working days. Amounts credited for administrative expenses are exempt.

FEMA: lending to and borrowing from Indian group companies

An IFSC financial institution or branch “shall be treated as a person resident outside India” if permitted or recognised as such by the Government of India or a Regulatory Authority (reg. 3, FEM (IFSC) Regulations 2015). Each flow between the GRCTC and an Indian group company is therefore cross-border. For the general rules, see the FEMA page and capital flows page.

Lending to Indian group companies (ECB). The FEM (Borrowing and Lending) (First Amendment) Regulations 2026 (FEMA 3(R)(5)/2026-RB, dated 9 February 2026) substituted Schedule I (the ECB framework). They apply “from the date of their publication in the Official Gazette” (reg. 1(2)); that date is not stated in the text read. Under the new Schedule I:

a recognised lender includes “A financial institution or a branch of a financial institution set up in IFSC”, as defined in the FEM (IFSC) Regulations (para 2(c));
an eligible borrower is any non-individual resident incorporated or registered under a Central or State Act and permitted ECB (para 1(1)); and
ECB may be in foreign currency or INR (para 3(1)).

A GRCTC registered as a finance company should be a “financial institution”, since the definition covers entities “engaged in rendering financial services or carrying out financial transactions” (reg. 2(b), FEM (IFSC) Regulations). The text does not name GRCTCs, so this is a reading. Each intra-group loan is checked against Schedule I loan by loan: borrower eligibility; recognised lender (above); currency; end-use restrictions; minimum average maturity; all-in-cost ceiling; loan registration number and reporting; and any sector-specific restrictions. Schedule I’s values for these are not set out here.

Other flows. IFSCA’s treasury permissions do not supply FEMA permission. Each Indian leg (borrowing, lending, guarantees, deposits, pooling) needs its own FEMA basis on the Indian side, and the Framework does not provide one. An Indian parent’s capital in the GRCTC is treated as overseas investment where required; IFSCA’s setup workflow lists “ODI-Capital and Funds Infusion (when required after IFSCA In-Principle approval)” as a step (step 7.d). No overseas investment rule was reviewed.

Tax: what is and is not settled

A “unit of an International Financial Services Centre” may deduct 100% of income from “the approved business activities” of an IFSC unit set up in an SEZ. The deduction runs for any 20 consecutive tax years out of 25 (s. 147(1)(b), (2)(b), (3)(c), Income-tax Act 2025). “Unit” takes its SEZ Act meaning, which includes “a Unit in an International Financial Services Centre” (s. 147(6)(b); s. 2(zc), SEZ Act). The claim needs a copy of the IFSCA registration (s. 147(4)(b)(ii)).

A GRCTC holding an LoA and an IFSCA registration appears to fit that wording. We found no CBDT or IFSCA statement on GRCTCs specifically. Eligibility depends on the centre being an IFSC unit with approved activities, which turns on the facts.

Three further points:

New units. A unit commencing on or after 1 April 2026 qualifies only if not formed by “splitting up or reconstruction or reorganisation or transfer of a business already in existence in India” (s. 147(5)). Moving an existing Indian treasury function is tested against this.
Rate and MAT. The Finance Bill 2026 Memorandum states that business income of IFSC units “after the expiry of period of deduction will be taxed at rate of 15%” (p. 48; also Budget Speech 2026-27, Annexure to Part B, item 4(vi)). Section 218 does not use those words. How MAT/AMT at 9% (s. 206) applies in the deduction years is not addressed in the guidance found. See GIFT City tax benefits and GIFT City tax.
Intra-group loans and “dividend”. Finance Act 2026, s. 35 substituted s. 2(40)(v) of the Income-tax Act 2025. An advance or loan between two group entities is not a “dividend” where one is a Finance Company or Finance Unit, the other is located outside India, and the group’s parent or principal entity is listed on a stock exchange outside India. The countries for the last two conditions are to be notified by the Central Government; no notification was checked. “Group entity” takes its meaning from the IFSCA (Payment Services) Regulations 2024 (Memorandum, p. 48).
Interest paid to non-residents. Interest payable by an IFSC unit to a non-resident on money borrowed on or after 1 September 2019 is excluded from the lender’s income (Schedule VI, Sl. No. 12).

Transfer pricing is a separate consideration. Intra-group interest, guarantee fees, pooling and service charges will need pricing support in India and in each counterparty’s jurisdiction.

Fees and the application

Fee	Amount	Source
Application	USD 1,000, one-time	Framework cl. 18(1); fee circular, Sch. I, 1.D.vi
Registration	USD 12,500, one-time	Same
Recurring	USD 25,000 a year	Same

A GRCTC that registers as a factor does not pay a separate registration or recurring fee for factoring (cl. 18(3)). Clause 18(2) refers to a 2023 fee circular, but that circular has been superseded. Payment now follows Circular IFSCA-DTFA/1/2026 (2 March 2026, corrected 13 March 2026), which applies from FY 2026-27 (1 April 2026) and under which the first year’s recurring fee is pro-rated (para 4.2).

The application goes through SWIT, with the list of service recipients (cl. 4). The SEZ and IFSCA steps are those for any unit: see the setup section of the entity and licence guide.

Fees are payable in USD to IFSCA’s USD account (para 13.1, Circular IFSCA-DTFA/1/2026). An applicant from India that is not already registered with IFSCA has the option to remit only the application fee and the registration fee in equivalent INR, at the FBIL USD-INR reference rate on the date of remittance (paras 13.2–13.3). That option does not extend to the recurring fee.

2021 circular vs 2025 Framework

Point	2021 circular	2025 Framework
Service recipients	“exclusively” Group Entities, with a FATF test on each recipient, subject to an exception for countries specified by the Government of India (para C)	Group Entities, the Parent’s Group Entities and branches; Indian residents allowed subject to FEMA (cl. 12)
FATF test	On the recipient’s domicile	On the Parent (cl. 3(2)(iv))
Group Entities	Holding, subsidiary, associate, branch, JV (para B(ii))	Ind AS-based links, related parties, common brand, 20% equity (cl. 2(1)(d))
Owned fund	Not stated in the circular	USD 0.2m; branch may hold at parent (cl. 6)
Currency	“freely convertible foreign currency only” (para G(i))	Specified foreign currencies in IFSC; others outside; SNRR account (cl. 16)
Staff	Not stated	Five qualified IFSC-based staff (cl. 3(2)(ii)); relaxable for up to one year (circular of 9 June 2025)
Fees	Not stated	USD 1,000 / 12,500 / 25,000 a year (cl. 18)

Common questions

What is a GRCTC in GIFT City? A finance company or Finance Unit registered under the FC Regulations to run treasury for its group from GIFT IFSC (reg. 5(1)(ii)(e); Framework cl. 1).

Can an Indian company set up a treasury centre in GIFT City? Yes. The Framework allows a company or a branch of a company “incorporated in India or outside India” (cl. 5), and recipients may be Indian residents (cl. 12(1)). FEMA governs the Indian side.

What is the minimum capital for a GIFT City treasury centre? A minimum owned fund of USD 0.2 million at all times. A branch may hold it at parent level (cl. 6).

Can a GRCTC lend to Indian subsidiaries? Probably, subject to FEMA. An IFSC financial institution is a recognised ECB lender (Sch. I, para 2(c), FEM (Borrowing and Lending) Regulations, as substituted in 2026), and a GRCTC appears to qualify, though the text does not name GRCTCs. That is one condition. The borrower must be permitted ECB (para 1(1)), and end-use, maturity, cost and reporting apply loan by loan. The IFSCA registration is not itself FEMA permission.

Can a GRCTC run group cash pooling? Yes. Liquidity management includes pooling, but the header account must be with an IBU or IBC (Annex II, row 7).

Is a GIFT City treasury centre’s income tax-free? Not automatically. Section 147 may apply if the GRCTC is an IFSC unit with approved activities. The Government’s stated intention is 15% after the deduction period; how MAT/AMT applies in the deduction years is not addressed in the guidance found.

Sources

Framework for Finance Company / Finance Unit undertaking the activity of Global / Regional Corporate Treasury Centres (F. No. IFSCA/24/2024-Banking-FC/01). IFSCA, 4 April 2025. ifsca.gov.in ; GRCTC page ifsca.gov.in
Framework for undertaking Global/Regional Corporate Treasury Centres Activities by Finance Company/Finance Unit in IFSC (F. No. 331/IFSCA/GRCTC/2021-22), repealed. IFSCA, 25 June 2021. ifsca.gov.in
IFSCA (Finance Company) Regulations, 2021, as amended up to 7 May 2026. IFSCA, 25 March 2021. ifsca.gov.in
IFSCA (Finance Company) (Amendment) Regulations, 2026 (IFSCA/GN/2026/009). IFSCA, 5 May 2026. ifsca.gov.in
Fee structure for the entities undertaking or intending to undertake permissible activities in IFSC (IFSCA-DTFA/1/2026). IFSCA, 2 March 2026, applicable from FY 2026-27. ifsca.gov.in
IFSCA (Banking) Regulations, 2020, as amended up to 14 July 2023, First Schedule; and IFSCA (Banking) (Amendment) Regulations, 2024 (IFSCA/GN/2024/004). IFSCA, 4 July 2024. ifsca.gov.in
Circular amending the SNRR account circular of 29 January 2025 (F. No. IFSCA-FMPP0BR/4/2024-Banking). IFSCA, 19 June 2026. Circular register: ifsca.gov.in
Workflow for Setting up in IFSC on the SWIT portal (v1.0). IFSCA, July 2026. ifsca.gov.in
Foreign Exchange Management (International Financial Services Centre) Regulations, 2015 (FEMA 339/2015-RB). RBI, 2 March 2015. rbi.org.in
Foreign Exchange Management (Borrowing and Lending) (First Amendment) Regulations, 2026 (FEMA 3(R)(5)/2026-RB). RBI, 9 February 2026. rbi.org.in
Income-tax Act, 2025, s. 147 (as amended by the Finance Act, 2026). Income Tax Department. incometaxindia.gov.in
Income-tax Act, 2025, Schedule VI. Income Tax Department. incometaxindia.gov.in
Finance Act, 2026 (No. 4 of 2026), ss. 35, 47 and 60. Gazette of India Extraordinary, 30 March 2026. Official URL for the Act PDF not located
Corrigendum to fee circular (IFSCA-DTFA/2/2026). IFSCA, 13 March 2026. Official URL not located
Amendment to the Framework for Finance Company/Finance Unit undertaking the activity of Global/Regional Corporate Treasury Centres (F. No. IFSCA/24/2024-Banking-FC/02). IFSCA, 9 June 2025. ifsca.gov.in
FAQs on Finance Company / Finance Unit (final version, 11 June 2024), including GRCTC FAQs. IFSCA. ifsca.gov.in
Memorandum explaining the provisions in the Finance Bill, 2026. Ministry of Finance, 1 February 2026. indiabudget.gov.in
Budget Speech 2026-27, Annexure to Part B. Ministry of Finance, 1 February 2026. indiabudget.gov.in

Corporate Treasury Centre in GIFT City: The GRCTC Framework