Global/Regional Corporate Treasury Centre in GIFT IFSC: Eligibility, Permissible Activities and Regulatory Fees
As business groups expand across jurisdictions, treasury management becomes increasingly complex. Multinational and diversified groups must manage liquidity across entities, arrange funding in multiple currencies, control foreign exchange and interest-rate exposure, maintain banking relationships and optimise the deployment of surplus funds.
A Global or Regional Corporate Treasury Centre, commonly referred to as a GRCTC, enables a business group to centralise these functions within a dedicated treasury platform. In India, GIFT International Financial Services Centre provides a regulated framework for establishing such treasury centres as a Finance Company or Finance Unit.
On April 4, 2025, the International Financial Services Centres Authority issued an updated framework for Finance Companies and Finance Units undertaking GRCTC activities. The framework supersedes the earlier circular dated June 25, 2021 and seeks to improve ease of doing business while aligning the regulatory structure with international treasury practices.
What is a GRCTC in GIFT IFSC?
A GRCTC is a centralised treasury platform established in an IFSC to provide treasury, funding, liquidity, investment, financial-risk-management and related advisory services to eligible entities within a business group.
The GRCTC framework operates under the International Financial Services Centres Authority (Finance Company) Regulations, 2021. An entity intending to undertake GRCTC activities must obtain registration from IFSCA as a Finance Company or Finance Unit.
Who can establish a GRCTC?
A GRCTC may be established in GIFT IFSC in either of the following legal forms:
- A company incorporated in India or outside India; or
- A branch of a company incorporated in India or outside India.
A company-based structure is registered as a Finance Company, whereas a branch-based structure is registered as a Finance Unit.
The applicant must possess, or undertake to establish, adequate infrastructure within the IFSC. This includes appropriate office space, equipment, communication facilities and operational systems necessary for carrying out the proposed treasury activities.
The applicant must also employ at least five qualified personnel based in the IFSC before commencing operations. The prescribed personnel strength must include a Head of Treasury and a Compliance Officer.
The parent of the applicant must not be situated in a jurisdiction identified by the Financial Action Task Force as a high-risk jurisdiction subject to a call for action. Additionally, the applicant should not have been refused authorisation or registration by IFSCA during the year preceding the application.
Minimum owned fund requirement
A Finance Company or Finance Unit undertaking GRCTC activities must maintain a minimum owned fund of USD 0.2 million at all times.
Owned fund broadly includes paid-up capital, free reserves, securities premium and eligible capital reserves, after deducting accumulated losses, intangible assets and deferred revenue expenditure.
In the case of a Finance Unit established as a branch, the required owned fund may be maintained at the parent level. This flexibility can be relevant for overseas or Indian companies considering a branch-based treasury structure instead of incorporating a separate subsidiary in GIFT IFSC.
Eligible group entities and service recipients
Entities may qualify as group entities through any of the following relationships:
- Parent and subsidiary;
- Joint venture;
- Associate;
- Related party;
- Common brand name; or
- Investment of 20% or more in equity shares.
A registered GRCTC may undertake permissible activities for its own group entities, group entities of its parent and branches of the parent or eligible group entities.
These entities are collectively referred to as Service Recipients. A service recipient may be a person resident in India or a person resident outside India under the Foreign Exchange Management Act, 1999.
Each service recipient must be registered under an applicable law with a competent or statutory authority in its home jurisdiction. The applicant must provide a list of proposed service recipients at the time of applying for registration. The GRCTC must thereafter maintain an updated list and provide it to IFSCA when called upon.
Where services are provided to Indian-resident entities, the proposed treasury arrangements must also be examined from a FEMA perspective. Regulatory feasibility may depend on the nature of the transaction, currency, funding route, pricing and relationship between the participating entities.
Permissible activities of a GRCTC
A Finance Company or Finance Unit registered for undertaking GRCTC activities may carry out the following activities for its eligible service recipients:
- Raising capital through the issuance of equity shares;
- Borrowing, including through inter-company deposits;
- Credit arrangements, including lending, credit guarantees, performance bonds and other credit facilities;
- Transacting or investing in financial instruments issued in IFSC or outside IFSC;
- Undertaking derivative transactions, including OTC and exchange-traded derivatives, for hedging risks on its own books or those of its service recipients, or for taking positions in financial instruments or markets;
- Foreign exchange transactions in currencies specified by IFSCA;
- Factoring and forfaiting, subject to obtaining registration under the applicable IFSCA regulations governing factors and assignment of receivables;
- Acting as a re-invoicing centre for financing the purchase and sale of goods on behalf of service recipients, without taking physical possession of such goods;
- Liquidity management, including pooling of funds, netting, cash concentration, optimisation of cash flows and working capital, processing of payments and investment of surplus funds;
- Maintaining relationships with financial counterparties, including banks, credit-rating agencies and other financial institutions, and undertaking treasury accounting, valuation, covenant testing, compliance reporting and audit coordination;
- Managing insurance and pension-related obligations of service recipients, including management and monitoring of insurance and pension arrangements;
- Providing advisory services relating to financial management and financial-risk management, including cash-flow forecasting, investment appraisal, tax planning, operational-risk management, hedging strategies and monitoring of financial risks;
- Providing advisory services relating to funding and capital-market activities, including capital-structure optimisation, liquidity planning, credit-rating management, portfolio management and diversification of funding sources;
- Acting as a holding company for permitted investments in group entities; and
- Undertaking any other activity notified under the IFSCA Act, subject to prior approval of the Authority.
Registration and commencement of operations
Applications must be submitted through IFSCA’s Single Window IT System. IFSCA may initially issue a provisional registration and, upon satisfaction of the prescribed conditions and payment of fees, grant a Certificate of Registration.
The entity may commence business only after receiving the Certificate of Registration and obtaining a valid Letter of Approval under the Special Economic Zones Act, 2005.
Operations must ordinarily commence within six months from the date of registration. IFSCA may grant an extension of up to three months where a properly supported application is submitted within the prescribed timeline.
Regulatory fee structure
The framework prescribes the following fees:
| Fee | Amount | Frequency |
|---|---|---|
| Application fee | USD 1,000 | One time |
| Registration fee | USD 12,500 | One time |
| Recurring fee | USD 25,000 | Annually |
The revised fee structure applies to existing GRCTCs from the beginning of financial year 2025–26.
Conclusion
The updated GRCTC framework provides a structured opportunity for multinational and diversified groups to centralise treasury operations in GIFT IFSC. Its scope extends beyond basic cash management and includes funding, investments, derivatives, credit support, re-invoicing, factoring, risk management and treasury advisory.
However, setting up a GRCTC requires more than regulatory registration. Groups must evaluate their ownership structure, service-recipient network, transaction volumes, staffing requirements, FEMA position, transfer-pricing model, tax implications, banking arrangements and governance framework.
A carefully designed GRCTC can become an effective regional treasury, financing and holding platform. The final structure should therefore be developed through an integrated assessment of regulatory eligibility, commercial substance, operational readiness and cross-border tax and exchange-control considerations.
