CROSS-BORDER
TEPA has applied between India and Switzerland, Norway, Iceland and Liechtenstein since 1 Oct 2025. Tariff cuts, origin proof, the investment goal and how it sits with the DTAAs.
Cross-Border
Written by CA Nandini Hasija, Krystal7 Consultants. Last updated 23 October 2026.
The India EFTA Trade and Economic Partnership Agreement (TEPA) has applied since 1 Oct 2025 between India and Switzerland, Norway, Iceland and Liechtenstein. India cuts duty on 82.7 percent of tariff lines covering 95.3 percent of EFTA exports. Make in India and PLI lines phase in over 5, 7 or 10 years. Article 7.1 sets an FDI objective of USD 100 billion over 15 years. Importers prove origin under Notification 59/2025-Customs (N.T.). Tax treaties are unchanged.
This page is for Swiss, Norwegian, Icelandic and Liechtenstein groups that own or plan an Indian subsidiary. It covers the tariff offer, the origin rules, the investment chapter and services. It also covers how TEPA sits with the India Switzerland tax treaty after the MFN suspension.
TEPA is a free trade agreement between India and the four EFTA states. It was signed in New Delhi on 10 Mar 2024 and entered into force on 1 Oct 2025. It has 14 chapters, including goods, rules of origin, services, investment promotion, intellectual property and sustainable development. It is India's first FTA with an investment and jobs objective.
The Ministry of Commerce announced the start date on 30 Sep 2025 in PIB release 2173138. EFTA and India issued a joint communiqué on 1 Oct 2025. The legal texts, annexes and schedules are on the Ministry of Commerce TEPA page.
The first chapters cover general provisions, trade in goods, trade remedies, SPS measures, TBT and trade in services. Then come investment promotion, intellectual property, government procurement and competition. The last four cover sustainable development, dispute settlement, institutions and final provisions. Rules of origin and trade facilitation sit as annexes to the goods chapter.
EFTA is not a customs union, so each party has its own schedule of concessions. India's schedule is Annex 2.C, with a separate offer to Iceland, Norway and Switzerland in Appendices 2.C.1 to 2.C.3. The schedules of Iceland, Norway and Switzerland are Annexes 2.D, 2.E and 2.F. Switzerland and Liechtenstein share a customs territory, so they give joint concessions (EFTA chapter factsheet).
The combined GDP of India and the EFTA states is around USD 5.4 trillion (EFTA news, 8 Oct 2026).
India offers concessions on 82.7 percent of its tariff lines, covering 95.3 percent of EFTA exports to India. More than 80 percent of imports from EFTA are gold, and the effective duty on gold is unchanged. For Make in India and PLI products, cuts phase in over 5, 7 or 10 years (PIB release 2173138).
The headline number is smaller than it looks. Take gold out and the share of non gold EFTA exports that gain a cut is not published in the official releases.
| India's TEPA offer | Figure | Source |
|---|---|---|
| Tariff lines with concessions | 82.7% | PIB 2173138, 30 Sep 2025 |
| Share of EFTA exports covered | 95.3% | PIB 2173138 |
| Gold in imports from EFTA | Over 80%, duty unchanged | PIB 2173138 |
| Staging for Make in India and PLI products | 5, 7 or 10 years | PIB 2173138 |
| Sensitive sectors kept out | Pharma, medical devices, processed food, dairy, soya, coal, some farm goods | PIB 2173138 |
| Products EFTA lists as gaining | Pharmaceuticals, machinery, watches, fertilisers, medicines, chemicals, minerals, fish | EFTA chapter factsheet |
The two official sources read differently on pharmaceuticals. PIB lists pharma and medical devices as protected. The EFTA factsheet lists pharmaceuticals among products whose Indian duty falls. Both can be true at line level, with some lines cut and others excluded. Check the eight digit line in India's schedule in Annex 2.C before you price a product.
Exporters of Swiss watches, chocolate and wine will want the year by year rates. The EFTA factsheet lists watches among the products whose Indian duty is removed, but gives no staging. Neither PIB nor EFTA publishes the rates for chocolate or wine. The rates sit in India's offer to Switzerland, Appendix 2.C.3, and its Attachment 1 for wine (HS 2204). Both are on the Ministry of Commerce TEPA page. Read your line there before you price.
EFTA states give concessions on 92.2 percent of their tariff lines, covering 99.6 percent of India's exports. That includes 100 percent of non agricultural products and concessions on processed farm goods (PIB release 2173138). Most Indian industrial goods already entered EFTA at zero duty.
The gains are on processed food, coffee, marine products and some farm lines. EFTA gives 0 percent duty on all coffee lines. TEPA locks in EFTA's existing 0 percent rate on leather and footwear. Gems and jewellery keep duty free access (PIB release 2173138).
If your Indian subsidiary exports to the Swiss or Norwegian parent, the duty saving at the EFTA border is modest for industrial goods. The bigger value is legal certainty. TEPA binds the zero rates, so an EFTA state cannot raise them without breaching the agreement.
The certificate of origin for Indian exports is the Indian one in Appendix 2.A.3. Indian authorised agencies issue it, or the exporter self declares it (Article 1 of the appendix).
Article 7.1 sets an objective for the EFTA states to raise FDI into India by USD 50 billion within 10 years of entry into force. A further USD 50 billion follows in the next 5 years. The aim is one million direct jobs in India. Portfolio investment does not count (PIB release 2173138).
The chapter relies on review rather than penalties. A sub committee reviews progress at regular intervals (EFTA chapter factsheet). If the target is not met after 15 years, India may start a three stage consultation. If India is still not satisfied, it may suspend concessions after a further grace period of three years. Any suspension must be proportionate and temporary.
| Stage | Period from 1 Oct 2025 | Milestone |
|---|---|---|
| First objective | 10 years, to 30 Sep 2035 | USD 50 billion of additional EFTA FDI |
| Second objective | Next 5 years, to 30 Sep 2040 | Another USD 50 billion, USD 100 billion in total |
| Review | Throughout | Sub committee reviews progress |
| Consultations | After 15 years, if the target is missed | Three stage consultation requested by India |
| Possible rebalancing | After a further 3 year grace period | India may suspend concessions, proportionately and temporarily |
The dates in the table are our arithmetic from the 1 Oct 2025 start. They are not printed in the agreement.
The Government launched an India EFTA Desk on 10 Feb 2025 as a single window for EFTA investors (PIB release 2101431; PIB backgrounder, 11 Oct 2025). It focuses on renewable energy, life sciences, engineering and digital transformation, and supports joint ventures and SME partnerships.
No. Article 7.1 is an objective of the EFTA states, measured in aggregate FDI flows. It places no investment duty on any company. The only consequence of a shortfall is India's right, after 15 years, consultations and a three year grace period, to suspend some trade concessions.
The EFTA governments promote investment through their own agencies. They do not direct private capital. The EFTA factsheet describes the chapter as built on historical trends, economic forecasts and expected spillovers from the agreement.
For a Swiss parent, the practical point is different. TEPA does not change how an investment enters India. The FEMA (Non Debt Instruments) Rules, 2019, sector caps and reporting rules apply as before. PIB reported Minister Piyush Goyal's assurance that 100 percent FDI is allowed in almost all sectors of interest (PIB release 2173968, 1 Oct 2025).
FDI counted towards the target is ordinary FDI. A share subscription by a Swiss parent in its Indian subsidiary is reported in Form FC-GPR within 30 days of allotment, like any other. Our Switzerland to India company guide covers set up.
Goods qualify if they are wholly obtained in a party or meet the product specific rule in Annexure A. Indian customs applies these rules through Notification 59/2025-Customs (N.T.) of 29 Sep 2025, in force from 1 Oct 2025. Proof is an approved exporter's origin declaration, an EUR.1 certificate, or an Indian certificate of origin, each valid for 12 months.
The notification sets out the Customs Tariff (Determination of Origin of Goods under the Trade and Economic Partnership Agreement between India and the EFTA States) Rules, 2025. CBIC made them under section 5(1) of the Customs Tariff Act, 1975. The notification is published in the Gazette of India and listed on CBIC's tax information portal.
| Point | TEPA rule as notified in India | Rule in Notification 59/2025 |
|---|---|---|
| Value cap | Caps on non originating materials vary by product, for example 60% of the ex works price, often as an alternative to a tariff shift | Annexure A |
| Sector caps | 65% for pharmaceuticals (Chapter 30); 70% for some Chapter 32 goods; 80% for polished stones (71.03) | Annexure A |
| FOB basis | Cap is 5 percentage points lower than the ex works cap | Annexure A |
| Tolerance | Non originating materials up to 10% of FOB or ex works value | 5(2) |
| Cumulation | Inputs originating in any party count as originating | 7 |
| Direct consignment | Transit allowed only with no processing and under customs control | 13 |
| Proof of origin | Approved exporter declaration, EUR.1, or Indian certificate of origin | 14 |
| Validity | 12 months from completion or issue; late proof only in exceptional cases | 14(3), 15(4) |
| Records | Exporter and importer keep 5 years | 16 |
| Verification | Request within 5 years; acknowledgement within 45 days; reply generally within 10 months | 18 |
The Swiss customs circular confirms the EFTA side. Swiss exporters use an origin declaration or an EUR.1. Only approved exporters may make out an origin declaration. It must be in English, in the set wording, and electronically signed (BAZG Circular R-30, 11 Aug 2025).
Box 8 of the EUR.1 must show the six digit HS code and the origin criterion, "WO" or "PSR". For an origin declaration, Swiss customs recommends adding the six digit HS code on the commercial document to ease import into India.
The circular also says TEPA does not prohibit duty drawback. Swiss exporters may claim drawback on imported inputs and still certify origin. The Indian rules govern only the import side.
The subsidiary claims at import in the bill of entry. It declares that the goods originate in an EFTA state, quotes the TEPA tariff notification serial, and enters the proof of origin details. Section 28DA of the Customs Act, 1962 and CAROTAR 2020 apply, as for every Indian FTA.
CAROTAR adds duties on the importer. It must hold the origin information in Form I and keep supporting papers for five years from the bill of entry (rule 4). If customs asks for information, the importer has 10 working days to reply (rule 5). These steps are set out in a CBIC training deck on CAROTAR.
Customs may verify with the EFTA authority. Under Notification 59/2025, the exporting party acknowledges a request within 45 days and generally replies within 10 months. It confirms the authenticity of an origin declaration within 45 working days. Goods can be released during verification on payment of duty or against security.
Customs can refuse the preference if the proof is incomplete, altered without authentication or out of date (CAROTAR rule 3(2)). It can extend a refusal to identical goods from the same exporter (rule 7). Our guide to rules of origin and CAROTAR explains each step.
A practical point for groups: a Swiss parent that is not an approved exporter must use an EUR.1 for every shipment. Approved exporter status saves time on regular intercompany flows. Ask the parent's customs team whether it holds that status.
India commits in 105 services subsectors. Switzerland commits in 128, Norway in 114, Iceland in 110 and Liechtenstein in 107 (PIB release 2173138). TEPA improves access for digital delivery, commercial presence and temporary entry of key staff, and provides for recognition of professional qualifications.
| Party | Services subsectors committed | Notes |
|---|---|---|
| India | 105 | Commitments to all four EFTA states |
| Switzerland | 128 | Highest number among EFTA states |
| Norway | 114 | Includes maritime interest |
| Iceland | 110 | |
| Liechtenstein | 107 |
The services chapter builds on GATS. It has annexes on financial services, telecom, movement of natural persons, recognition of qualifications and maritime personnel (EFTA chapter factsheet). Mutual recognition is planned for nursing, chartered accountancy and architecture (PIB release 2173138).
For an Indian subsidiary, the services chapter matters when staff travel to the EFTA parent. The movement of natural persons annex gives more certainty on entry and temporary stay. Domestic visa and work permit rules still apply in each EFTA state.
Services exports from the Indian subsidiary to the parent stay zero rated under GST if they meet the export of services test. TEPA does not change that.
Three things change. Imports from the EFTA parent can pay lower basic customs duty if the origin proof is in order. The Indian subsidiary must run an origin file under CAROTAR. Exports to the parent gain bound zero duty and clearer staff mobility.
| Area | Change under TEPA | What to do |
|---|---|---|
| Imports from the parent | Lower basic customs duty on qualifying lines, often staged | Map each HSN code to Annex 2.C and its staging |
| Origin proof | Origin declaration by an approved exporter, or EUR.1 | Confirm the parent's approved exporter status |
| Origin file in India | Form I information and five year records | Keep a bill of materials and cost sheet per product |
| Landed cost | Lower duty changes the subsidiary's margin | Review transfer prices for the year of each cut |
| Exports to the parent | Zero duty bound on industrial goods | Obtain Indian certificates of origin where needed |
| Investment | Article 7.1 objective, no company obligation | Report FDI as usual under FEMA |
| Professional services | Recognition talks for nursing, accountancy, architecture | Watch for any recognition agreement before relying on it |
The transfer pricing effect is easy to miss. If customs duty falls and the transfer price stays the same, the Indian distributor's margin rises. Revisit the benchmark in the year of the cut. Our page on transfer pricing documentation covers the file.
A Swiss parent that sends managers to India should still watch permanent establishment risk. TEPA does not change that test. See our note on permanent establishment risk.
For the setup itself, our country guides cover the process, cost and timeline for a parent in Switzerland, Norway, Iceland and Liechtenstein.
TEPA is a trade agreement and does not change withholding tax. Dividends, interest and royalties from an Indian subsidiary to a Swiss parent follow the Income Tax Act, 2025 and the India Switzerland DTAA. India applies no lower MFN rate, because the Supreme Court held in Nestle SA that MFN needs a Government notification.
The background runs as follows. The protocol to the India Switzerland DTAA has an MFN clause. Nestle SA, a Swiss company, argued that India's later treaties with Lithuania and Colombia cut its dividend rate. On 19 Oct 2023 the Supreme Court held that the MFN benefit needs a notification under section 90(1) of the Income Tax Act, 1961. That is now section 159 of the Income Tax Act, 2025. It also held that the third country must have been an OECD member when India signed with it.
Switzerland had applied the MFN rate on its side. On 11 Dec 2024 the Swiss Federal Department of Finance said it would stop applying the MFN clause from 1 Jan 2025, citing lack of reciprocity. Swiss tax on dividends due to Indian residents from that date is capped at 10 percent instead of 5 percent (Swiss notice of 11 Dec 2024). The notice says the step does not affect the free trade agreement or Swiss investments in India.
| Treaty partner | Dividend withholding rate an Indian subsidiary applies (%) | MFN position | Notes |
|---|---|---|---|
| Switzerland | 10% under the DTAA | India applies no MFN rate; Switzerland suspended its MFN application from 1 Jan 2025 | Relevant to Swiss parents and to Indian groups with Swiss subsidiaries |
| Norway | 10% under the DTAA | No MFN issue in India's practice | |
| Iceland | 10% under the DTAA | No MFN issue in India's practice | |
| Liechtenstein | Domestic rate under section 207 of the Income Tax Act, 2025 (old section 115A), plus surcharge and cess | Not applicable | No comprehensive DTAA in the Income Tax Department's treaty rate table |
The Income Tax Department's table of tax rates under DTAAs shows a 10 percent dividend rate for Switzerland, Norway and Iceland. It lists no entry for Liechtenstein. The Swiss notice of 11 Dec 2024 confirms the 10 percent Swiss rate from its side.
So for a Swiss parent with an Indian subsidiary, the MFN suspension changes nothing on the Indian side. India was already applying the treaty rate. The suspension matters to Indian companies that hold Swiss subsidiaries, because Swiss withholding on their dividends rose from 1 Jan 2025.
To claim the treaty rate, the Swiss parent gives a tax residency certificate and Form 41 (old Form 10F). Section 159(8) and rule 75 govern the form. See our pages on Form 10F and the TRC and dividends to a foreign parent. Our MFN clause note covers the Nestle ruling in more depth.
TEPA leaves Indian FDI rules, tax treaties, GST and the Companies Act as they are. It cuts basic customs duty on qualifying goods and binds services commitments. Annual compliance for a Swiss or Norwegian owned subsidiary stays the same, from ROC filings to transfer pricing.
FDI entry stays under the FEMA (Non Debt Instruments) Rules, 2019 and the consolidated FDI policy. Most sectors are on the automatic route. See our page on FDI automatic route sectors.
GST stays the same. IGST is still payable on imports on the assessable value plus customs duty. The Social Welfare Surcharge falls with basic duty, because it is a percentage of it.
Transfer pricing and customs valuation of related party imports apply as before. So does the resident director rule in section 149(3) of the Companies Act, 2013. TEPA has no investor state dispute settlement chapter in its list of chapters. Protection of an Indian investment rests on Indian law and the courts.
| Date | Before | After | Instrument or source |
|---|---|---|---|
| 1 Jan 2025 | Switzerland applied a 5% MFN rate on dividends to Indian residents | Swiss tax capped at the 10% treaty rate | Swiss Federal Department of Finance notice, 11 Dec 2024 |
| 10 Feb 2025 | No dedicated investor desk | India EFTA Desk launched as a single window | PIB 2101431 |
| 1 Oct 2025 | TEPA signed but not applied | TEPA in force; Indian origin rules apply | Notification 59/2025-Customs (N.T.); PIB 2173138 |
| 10 Mar 2026 | TEPA in force for five months | Government marks two years since signing | PIB 2237451 |
| 7 Oct 2026 | No anniversary review | Prosperity Summit in New Delhi marks one year in force | EFTA news, 8 Oct 2026 |
This page first went up on 25 Feb 2026. These events came after that date.
A Swiss parent sells precision components to its Indian subsidiary. Assume the product specific rule caps non originating materials at 60 percent of the ex works price. These figures are for the arithmetic only.
Origin test on the ex works basis:
Origin test on the FOB basis:
If the steel price rises and non originating materials reach CHF 62, the ex works share is 62 percent. The part fails the 60 percent cap and pays standard duty.
Duty saving. Annual imports are INR 5,00,00,000 in assessable value. Assume standard basic customs duty of 7.5 percent and a TEPA rate of 0 percent once staging ends. Assume a Social Welfare Surcharge of 10 percent of basic duty.
Dividend. The subsidiary declares a dividend of INR 2,00,00,000 to the Swiss parent. At the 10 percent treaty rate, tax withheld is INR 20,00,000.
The parent needs a Swiss TRC and Form 41. The bank remits after Forms 145 and 146, because dividends are not on the rule 220 exempt list. Tribunals have held that surcharge and cess do not apply on top of a treaty rate. This is case law practice, not a rule in the Act.
If you want help with the line by line mapping or the origin file, our foreign subsidiary team can do it.
TEPA entered into force on 1 Oct 2025. India and the four EFTA states signed it in New Delhi on 10 Mar 2024. The Ministry of Commerce announced the start date on 30 Sep 2025 in PIB release 2173138. CBIC notified the origin rules as Notification 59/2025-Customs (N.T.) on 29 Sep 2025, effective 1 Oct 2025.
TEPA covers India and the four EFTA states: Switzerland, Norway, Iceland and Liechtenstein. EFTA is not a customs union, so each state has its own schedule. Switzerland and Liechtenstein share a customs territory and give joint concessions. EU member states are not covered; their trade with India falls under the separate India EU FTA.
India offers concessions on 82.7 percent of tariff lines, covering 95.3 percent of EFTA exports. Over 80 percent of imports from EFTA are gold, and the effective duty on gold is unchanged. Cuts on Make in India and PLI products phase in over 5, 7 or 10 years. Check each line in Annex 2.C.
For goods from EFTA, the importer needs an origin declaration by an approved exporter or an EUR.1 movement certificate. Both are valid for 12 months from completion under rule 14 of Notification 59/2025-Customs (N.T.). The importer enters the details in the bill of entry and keeps the Form I file under CAROTAR 2020.
No. Under TEPA only approved exporters in EFTA states may make out an origin declaration. Other exporters must use an EUR.1 certificate issued by customs. Swiss Circular R-30 of 11 Aug 2025 says the declaration must be in English, in the set wording, and electronically signed.
It depends on the product. Many rules in Annexure A cap non originating materials as a share of the ex works price, for example 60 percent. Pharmaceuticals in Chapter 30 use a tariff shift or a 65 percent cap. When the test uses FOB value, the cap is 5 percentage points lower. Some lines use a tariff shift rule instead.
No. Article 7.1 is an objective of the EFTA states. It aims to raise FDI into India by USD 50 billion in 10 years and another USD 50 billion in the next 5. Portfolio investment is excluded. If the target is missed, India may consult after 15 years and suspend concessions only after a three year grace period.
No. TEPA is a trade agreement. Dividend withholding follows the Income Tax Act, 2025 and the India Switzerland DTAA. The parent claims the treaty rate with a tax residency certificate and Form 41 under section 159(8). After the Nestle SA ruling, an MFN rate needs a notification, and we have seen none for Switzerland.
On 11 Dec 2024 Switzerland announced it would stop applying the MFN clause of the DTAA protocol from 1 Jan 2025. It cited lack of reciprocity. Swiss tax on dividends to Indian residents rose from 5 percent to the 10 percent treaty cap. India's withholding on payments to Swiss companies did not change, because India never applied the MFN rate.
TEPA's list of 14 chapters has an investment promotion chapter but no investment protection or investor state dispute settlement chapter. Disputes under TEPA are between states, through consultations and arbitration under Chapter 12. A Swiss investor's protection in India rests on Indian law and the Indian courts.
TEPA gives more certainty on temporary entry of key staff under its annex on movement of natural persons. It also provides for mutual recognition talks for nursing, chartered accountancy and architecture. Domestic visa and work permit rules in each EFTA state still apply. Check the state's schedule in Annex 6.F before a secondment.
Yes. CAROTAR 2020 applies to every preferential claim in India under section 28DA of the Customs Act, 1962. The importer holds Form I information, keeps records for five years and replies to customs within 10 working days. Where CAROTAR conflicts with the TEPA origin rules, the agreement's rules prevail under CAROTAR rule 8(3).
Yes. Indian exporters prove origin with a certificate of origin in the Appendix 2.A.3 format. Indian authorised agencies issue it, or the exporter self declares it. It must be issued within 5 working days of export, or retrospectively within one year marked "ISSUED RETROSPECTIVELY". Exporter and issuer keep copies for five years.
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WRITTEN BY
Nandini Hasija is a co-founder of Krystal7. She leads brand, business development and marketing, and works with founders to define their engagement. She is a Chartered Accountant and achieved All India Rank 49 in the CA examinations.
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IncorporationThe structure, steps, licences, costs and transfer pricing model for a foreign parent setting up an Indian software subsidiary or dev center.
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IncorporationHow a foreign parent sets up an Indian manufacturing entity: FDI route, the licence map by authority, honest timelines and the tax position in 2026.
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IncorporationThe FDI position, registration steps, environmental and safety licence map, and costs for foreign investors entering India's chemical sector.
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Cross-BorderThe five types of India advisers compared honestly for foreign founders: who each suits, the questions that expose a bad fit, real fee ranges, and where Krystal7 Consultants fits.
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Country GuidesForeign subsidiary registration in India creates an Indian company controlled by an overseas parent. The work includes an investment review, overseas documents, incorporation and the steps needed to fund and operate the company. Registration alone does not complete bank onboarding or foreign investment reporting.
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Country GuidesThe questions global founders actually ask before an India entry: what FEMA compliance means, who is responsible, how registration works from abroad, what it honestly costs, and the calendar that follows.
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IncorporationYes, a foreign-owned Private Limited company can register on Udyam. The revised thresholds, the portal steps, and what changes when the entity has FDI.
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IncorporationThe SPICe+ form on the MCA portal, part by part: name reservation, the Part B fields that cause resubmissions, linked forms, 2026 fees and stamp duty, documents and a realistic timeline.
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IncorporationThe right company registration provider for a foreign founder should assess the investor and proposed activity before quoting the filing. Compare the full scope through banking and investment reporting, the people responsible and the recurring compliance work. A certificate alone does not show that the business is ready to operate.
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IncorporationForeign founders can register a company in India, subject to the proposed activity, investment route and ownership checks. Decide whether you will invest personally or through an existing overseas company before preparing documents. A parent company should use the foreign subsidiary registration service to plan its corporate ownership and reporting.
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IncorporationThe truth about top rated online company registration services in India for 2026: how rankings are made, real costs, 8 to 10 working day timelines, and how to actually choose.
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Cross-BorderChoosing your India entry route in 2026: subsidiary, branch, LO or LLP compared on control, tax, FEMA and speed, with a decision framework for founders.
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Cross-BorderHow India's Production Linked Incentive schemes work in 2026, which sectors they cover, what Uttar Pradesh and Tamil Nadu add, how incentives are taxed under the Income Tax Act, 2025, and a checklist for a foreign manufacturer.
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IncorporationWho qualifies for DPIIT startup recognition under the February 2026 notification, why a foreign subsidiary does not, how to apply on NSWS, the benefits, the section 140 tax holiday and the usual rejection reasons.
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Cross-BorderHow CBIC's AEO programme works in India: the four tiers, eligibility, benefits, monthly deferred duty from 1 Mar 2026, mutual recognition, the application and whether a foreign owned subsidiary should apply.
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Cross-BorderHow customs duty in India is built from BCD, SWS, AIDC and IGST, how customs values imports from a foreign parent, how the bill of entry works on ICEGATE, and what drawback and advance authorisation save.
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IncorporationHow an Indian company issues shares to foreign investors by private placement under section 42 and rule 14, with PAS-4, the 200 person limit, deadlines, FEMA pricing and FC-GPR.
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Cross-BorderWhich countries have a social security agreement with India, how a certificate of coverage exempts posted workers, how EPFO issues one for Indian staff going abroad, totalisation, PF withdrawal and the 2026 scheme.
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Cross-BorderBengaluru, Hyderabad, Pune or Gurugram for a foreign tech subsidiary: talent, office costs, state IT and GCC policies, professional tax, shops and establishments law, lease stamp duty and a decision table.
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Cross-BorderHow the Budget 2026 data centre tax holiday works under Schedule IV serial 13C, what changed in August 2026, the 15 percent safe harbour, infrastructure status, state policies, power, DPDP localisation and the FDI route.
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Cross-BorderWhat an Indian importer must declare, hold and produce under section 28DA and CAROTAR 2020, how customs verifies a claim, and how it works for imports under the UAE, Australia, UK and EFTA deals.
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IncorporationWhat the memorandum and articles of a foreign owned Indian subsidiary must contain under sections 4 and 5, what Table F leaves out, the clauses a foreign parent should add, signing in SPICe+, and how to alter them later.
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Cross-BorderHow a foreign group sets up in GIFT IFSC: the IFSCA framework, funds, banking units, leasing, fintech and in house centres, the section 147 tax holiday, currency, FEMA status, approvals, and a Singapore and Dubai comparison.
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Cross-BorderThe 6 Feb 2026 India US framework, the 2025 tariff escalation to 50 percent, what changed after the Supreme Court ruling, and the transfer pricing and customs effects for an Indian subsidiary.
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Cross-BorderWho must register with the FRRO, the 14 day deadline under the Immigration and Foreigners Rules, 2025, e FRRO steps, documents, the certificate of registration, address changes, departure, penalties and the employer's duties.
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Cross-BorderHow a startup moves its holding company from the US or Singapore to India, comparing the inbound merger, share swap and share purchase routes, with FEMA approvals, pricing, shareholder tax, timelines and lessons.
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Cross-BorderThe India EU FTA was concluded on 27 Jan 2026 but is not yet signed or in force. Tariff cuts by sector, the origin rules, services and what it does not change for an EU parent.
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IncorporationHow Indian private companies issue sweat equity shares under section 54 and rule 8, with limits, valuation, lock in, FEMA rules for non residents, tax as a perquisite and ESOP comparison.
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Cross-BorderHow a foreign company sets up an SEZ unit in India: Form F, the Letter of Approval, the bond, net foreign exchange, tax after the section 10AA sunset, GST zero rating, IT units, exit and the 2025 and 2026 reforms.
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IncorporationThe documents, beneficial owner checks and foreign director KYC an Indian bank needs for a new subsidiary, how share capital should arrive, the FIRC and FC-GPR link, EEFC rules and a realistic timeline.
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Cross-BorderHow a foreign owned Indian company gets an Importer Exporter Code from DGFT, when service exporters need one, the April to June update, deactivation, and the links to customs, GST and FEMA export reporting.
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Cross-BorderHow a foreign parent seconds staff to an Indian subsidiary: the agreement, the real employer test, GST after Northern Operating Systems, PE and TDS after Centrica, payroll and provident fund, with a checklist.
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IncorporationEvery Indian company needs one director who stays in India for 182 days in the financial year. How foreign groups fill the seat, the forms, the liability, the first year rule and the section 172 penalty.
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Cross-BorderHow a foreign group sets up a global capability centre in India, from entity choice and cost plus pricing to the 15.5 percent safe harbour, SEZ or STPI, GST on exports, PE risk, payroll and the yearly filings.
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FEMA & RBIIndia has no direct conversion of a branch or liaison office into a subsidiary. Here are the steps in order, from incorporation and asset transfer at book value to GST, staff, AD bank closure, Form FC-2, PAN and TAN.
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FEMA & RBIHow the Overseas Investment Rules and Regulations 2022 work for an Indian company that sets up or buys a foreign entity in 2026: ODI vs OPI, the 400 percent limit, Form FC and UIN, the two layer rule, APR and late fees.
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FEMA & RBIHow a foreign company opens and runs a branch or project office in India in 2026: the eight permitted activities, the profit and net worth test, AD bank approval, the 35 percent tax rate, AAC, FC-3, profit remittance and closure.
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FEMA & RBISOFTEX stopped applying to software exports invoiced from 1 October 2026, when FEMA 23(R)/2026-RB came into force. What to do with September invoices, how the monthly EDF replaces the form, and the nine month realisation rule.
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FEMA & RBISince 1 October 2026 every exporter of services and software files a monthly Export Declaration Form (EDF) under FEMA. Who files it, where, the due dates, the nine month realisation rule and what a missed EDF costs.
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FEMA & RBIThe legal line between FDI and FPI in India: the NDI Rules 10 percent test, SEBI registration, reclassification within five trading days, tax under the Income Tax Act, 2025, reporting and the right route for a foreign parent.
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FEMA & RBIHow FEMA prices shares issued or transferred to non residents in 2026: rule 21 floor and ceiling, who values, DCF, the 90 day report, CCPS and CCD conversion, swaps, angel tax after its repeal, and rule 57 under the Income Tax Act, 2025.
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FEMA & RBIHow an Indian company files PAS-3 when a foreign investor takes shares: the 30 and 15 day clocks, attachments by route, fees, the order with FC-GPR, penalties and fixing a missed return.
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FEMA & RBIWhat RBI purpose codes are, what P0802 and P0807 mean after SOFTEX ended on 1 Oct 2026, the codes for service exports, FDI and payments to a foreign parent, and how to fix a wrong code with your bank.
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FEMA & RBIHow shares of an Indian Private Limited company move between a resident and a non resident in 2026: FEMA pricing, SH-4 and demat, stamp duty, FC-TRS within 60 days, deferred payment, capital gains, TDS and treaties.
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FEMA & RBIWhat a FIRC and an eBRC are, how to get each from your bank and the DGFT portal, the GST refund link, the 2026 FEMA export rules with EDF and nine month realisation, and fixes for missing certificates.
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FEMA & RBIHow an EEFC account works for a foreign owned Indian company or exporter in 2026: the 100 percent credit rule, permitted debits, the monthly conversion rule, interest, GST refunds, worked examples and a checklist.
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FEMA & RBIHow a foreign parent lends to its Indian subsidiary under the 2026 ECB rules: who can lend, the USD 1 billion limit, end uses, Form ECB 1 and ECB 2, late fees, withholding tax and transfer pricing.
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FEMA & RBIHow an Indian subsidiary runs a section 62(1)(a) rights issue for its foreign parent in 2026: offer periods, FEMA pricing on renounced shares, demat, PAS-3 and FC-GPR within 30 days, with a worked example.
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FEMA & RBIWho files the Annual Performance Report for overseas direct investment, the 31 December due date, when unaudited accounts are allowed, how AD banks file it in 2026, and the flat INR 7,500 late fee.
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FEMA & RBIA practical guide for foreign founders on identifying FDI automatic route sectors in India, understanding when government approval applies, and what to confirm before incorporating or accepting investment.
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FEMA & RBIForm FC-GPR, also written FCGPR: what it reports, the 30 day clock from allotment, the FIRMS portal steps through your AD bank, the certificates the form needs, and what a late filing costs.
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FEMA & RBIA practical guide for foreign founders on FDI reporting requirements in India, covering when RBI reporting applies, which filings to prepare, common mistakes, and when to bring in a compliance advisor.
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FEMA & RBIEvery legal route from an Indian subsidiary to its foreign parent with 2026 rates: dividends under treaty, royalties, buyback after April 2026, and the filings banks actually check.
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FEMA & RBIA step by step guide for foreign investors allotting shares in an Indian company: FEMA and Companies Act requirements, Automatic versus Approval Route, FMV pricing under FEMA valuation norms, FC-GPR filing on the FIRMS portal, and the post allotment compliance calendar covering PAS-3, annual return, and FLA.
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FEMA & RBIA practitioner walkthrough of FEMA compounding under the 2024 Rules: PRAVAAH filing, the INR 10,000 fee, penalty caps and the 180 day order timeline.
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FEMA & RBIThe full FDI compliance map for foreign owned companies in India: FC-GPR, FCTRS, FLA, sectoral caps and the penalties for getting reporting wrong.
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FEMA & RBIFC-GPR and FC-TRS are the two FEMA forms every foreign investor in an Indian company eventually meets. This guide sets out the difference between them in one table, explains when each applies, the 30 and 60 day filing clocks, and how to file correctly on the FIRMS portal.
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FEMA & RBIFC-GPR filing for foreign investment in India: the 30 day timeline, FIRMS portal steps, documents, LSF for delays and how to file without rejections.
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FEMA & RBILate or defective FC-GPR? Understand LSF regularisation versus compounding under the 2024 FEMA Rules, the PRAVAAH process, fees and timelines.
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FEMA & RBIHow Indian exporters net export receivables against import payables with the same overseas buyer, supplier or their group companies under FEMA, with the AD bank's role, EDPMS and IDPMS closure, write off limits and documents.
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FEMA & RBIHow FEMA treats OCI cardholders who invest in or direct Indian companies, with repatriation and non repatriation routes, FEMA and tax residence, DIN and KYC, Press Note 3, property and bank accounts.
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FEMA & RBIHow RBI computes the late submission fee for delayed FC-GPR, FC-TRS, LLP, ODI, FLA and ECB filings, the three year window, the cap, how to pay, the 2026 ECB changes and when compounding takes over.
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FEMA & RBIHow foreign partners invest in an Indian LLP under Schedule VI of the NDI Rules, with the sector test, designated partners, pricing, Form LLP(I) and LLP(II), conversion, tax and when an LLP fits.
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FEMA & RBIHow a foreign company merges into an Indian company under section 234 and rule 25A, the 2024 fast track for a foreign parent and its subsidiary, FEMA deemed approval, two year windows, tax and stamp duty.
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FEMA & RBIHow an Indian company pays a foreign supplier or its parent in advance for goods or services under the FEMA import rules in force from 1 Oct 2026, with guarantees, IDPMS, time limits and repatriation.
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FEMA & RBICase note on published RBI compounding orders for late FC-GPR, ARF and FC-TRS reporting and late share issues, with the amounts RBI charged, the compounding matrix, the late submission fee route and what to do now.
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FEMA & RBIHow rule 9(6) of the NDI Rules lets buyers and sellers defer, escrow or indemnify up to 25 percent of the price for 18 months, and how pricing, FC-TRS, escrow accounts, TDS and capital gains timing work.
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FEMA & RBIHow foreign investors fund Indian companies with CCDs, CCPS, warrants and convertible notes, with the NDI Rules, conversion pricing, coupons, tax, FC-GPR, Form CN and company law steps.
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FEMA & RBIThe time limit to realise and repatriate export value under FEMA for goods and services, the 2025 and 2026 changes, EDPMS, extension, set off, reduction and write off, and the GST refund consequences.
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FEMA & RBIHow rule 23 of the NDI Rules treats investment by a foreign owned or controlled Indian company, with the ownership and control tests, caps, pricing, the funds rule, Form DI and the annual auditor certificate.
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FEMA & RBIWhen an Indian company or foreign owned subsidiary must hold a Legal Entity Identifier under RBI rules for cross border payments, bank loans, forex deals and RTGS, and how to get and renew one.
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FEMA & RBIWhat Press Note 3 (2020) requires, the seven countries it covers, the 2026 beneficial owner test, the 10 percent automatic route, DPIIT reporting, approval timelines and the filing steps.
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FEMA & RBIHow an Indian subsidiary turns a foreign parent loan, ECB interest, import payables or pre incorporation costs into shares, with the Companies Act route, FEMA conditions, pricing, filings, tax and a worked example.
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Transfer PricingA practical guide for foreign founders on India's safe harbour rules for transfer pricing, covering when they apply to related party transactions, how they fit into compliance, and what to check before relying on them.
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Transfer PricingWho files Part A and Part B of Form 56, when an Indian subsidiary files Form 58 or the CbC report itself, the 2026 and 2027 due dates, penalties under sections 442 and 459, and two worked examples.
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Transfer PricingA practical guide for foreign founders on when Form 3CEB applies to an Indian entity, what to prepare for the chartered accountant, and how to avoid missed portal actions around transfer pricing reporting.
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Transfer PricingThe six prescribed methods under section 165 of the Income-tax Act, 2025 (formerly section 92C) with a worked example of each, the 1 to 3 percent tolerance range, safe harbour, and Form 3CEB documentation.
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Transfer PricingA practical guide for foreign founders on transfer pricing documentation requirements in India, covering local file, master file, intercompany agreements, benchmarking, and when to bring in an advisor for an Indian subsidiary.
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Transfer PricingCase note on the Delhi High Court rulings that decide management fee disputes for Indian subsidiaries: benefit, duplication, shareholder costs, allocation keys, aggregation, the 2026 safe harbour and the documents that win.
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Transfer PricingHow India taxes a management fee paid to a UAE parent: no FTS article in the treaty, PE risk, TDS and Forms 145 and 146, reverse charge GST, the benefit test, disallowance risks and UAE corporate tax, with a worked example.
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Income Tax & TDSHow an Indian company claims credit for tax withheld abroad in 2026: rule 128 and Form 67 for AY 2026-27, rule 76 and Forms 44 and 45 from tax year 2026-27, due dates, documents, disputes and worked examples.
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Income Tax & TDSHow India's General Anti Avoidance Rule works for foreign groups in 2026: Chapter XI of the Income Tax Act, 2025, the INR 3 crore test, grandfathering, the Approving Panel, PPT and LOB, and the substance file.
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Income Tax & TDSHow the India Netherlands DTAA taxes a Dutch company in 2026: 10 percent rates, the MFN clause after Nestle SA, share sales under Article 13(5), PE without a service clause, the MLI and Form 41.
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Income Tax & TDSHow the India Mauritius DTAA taxes a Mauritius company in 2026: treaty rates, source taxation of share gains after the 2016 protocol, grandfathering, Article 27A, the 2024 PPT protocol, Tiger Global, TRC and substance.
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TaxHow the India Singapore DTAA taxes a Singapore company in 2026: treaty rates, the make available test, capital gains after 2017, Article 24A, the MLI principal purpose test, PE triggers, Form 41 and substance.
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Income Tax & TDSWhen a foreign company becomes tax resident in India under POEM in 2026: section 6(10), CBDT Circular 6 of 2017, the active business test, the INR 50 crore threshold, founder risk and the tax cost.
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Income Tax & TDSHow India taxes RSUs and ESOPs that a foreign parent grants to staff of its Indian subsidiary in 2026: perquisite value under rule 15, TDS, cross charges, FEMA, capital gains, Schedule FA and Form 44.
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Income Tax & TDSHow the India Germany DTAA taxes a German company in 2026: the flat 10 percent rates, managerial fees, the missing service PE rule, capital gains, the MLI position, the Nestle MFN ruling and Form 41.
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Income Tax & TDSHow a foreign company gets a lower or nil TDS certificate in Form 128 under section 395 and rule 213: who can apply, documents, how the officer sets the rate, validity, the payer's Form 144 entry, and a UK SaaS example.
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Income Tax & TDSWhich return a foreign owned company in India files, the extended AY 2026-27 due dates, the ITR-6 schedules foreign owners trigger, the 22 percent regime and MAT credit choice, late filing costs and the move to the 2025 Act.
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Income Tax & TDSHow a foreign company or foreign national gets an Indian PAN in 2026: Form 96 and Form 95 replace Form 49AA, the apostilled registration certificate, fees, the Indian representative, rule 217 relief from higher TDS, and two worked examples.
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Income Tax & TDSHow an Indian subsidiary or a foreign company gets a TAN under section 397 of the Income Tax Act, 2025: Forms 134 and 135, rule 216 timing, documents, the INR 10,000 penalty, and the TDS work that follows.
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Income Tax & TDSHow the India UAE DTAA taxes a UAE company in 2026: who counts as a UAE resident, treaty rates, technical fees without an FTS article, free zone companies, capital gains, the MLI principal purpose test, PE, UAE corporate tax and documents.
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Income Tax & TDSHow the India UK DTAA taxes a UK company in 2026: Articles 11 to 14 rates, the make available test, service PE day counts, capital gains under Indian law, the MLI principal purpose test and Form 41.
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Income Tax & TDSHow the India US tax treaty taxes a US company in 2026: dividend, interest and royalty caps, fees for included services and the make available test, service PE, Article 24 LOB, capital gains, Form 41 and Form 6166.
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Income Tax & TDSWhat a non resident needs to claim treaty rates in India in 2026: the foreign TRC, Form 41 (old Form 10F) filed online, PAN or rule 217 details, validity rules, and Forms 42 and 43 for an Indian company's own TRC.
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Income Tax & TDSSection 63 of the Income Tax Act, 2025 keeps the INR 1 crore and INR 10 crore tax audit limits. See who needs an audit, the FY 2025-26 forms and dates, Form 26 from tax year 2026-27 and the new flat fee.
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Income Tax & TDSA section and form map from the 1961 Act to the Income Tax Act, 2025 for foreign owned subsidiaries, with the FY 2025-26 transition rule, tax year 2026-27 due dates and the 2026 MAT change.
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Income Tax & TDSA practical guide for foreign founders on how permanent establishment risk arises in India through employees, contracts, offices, and vendors, and how to structure India activity to reduce that exposure before scaling up.
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Income Tax & TDSForms 15CA and 15CB became Forms 145 and 146 on 1 Apr 2026. The four parts of Form 145, the rule 220 exemptions, treaty claims, portal steps, penalties and a worked royalty example.
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Income Tax & TDSThe corporate tax rate in India for foreign companies is 35 percent plus surcharge and cess. Full rate table with effective rates, DTAA withholding relief and the subsidiary comparison.
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Income Tax & TDSHow an Indian company deducts tax on royalty, fees, interest and dividends paid abroad in 2026, with section 393 and 207 rates, treaty rates for eight countries, rule 217, Forms 41, 128, 144 and 131, and a US example.
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TaxFor a foreign owned subsidiary, GST is not just registration, it is export refunds, reverse charge and a monthly filing rhythm. Here is a ranked, honest 2026 guide and who each firm suits.
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TaxCross border tax for founders in India: permanent establishment risk, withholding tax, treaty relief and transfer pricing, explained for 2026.
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TaxWhen minimum alternate tax applies to foreign companies and Indian subsidiaries: section 115JB and section 206, the 14 percent final MAT, book profit, the foreign company exclusions, MAT credit and the section 200 choice.
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TaxHow the single tax year in section 3 of the Income Tax Act, 2025 replaces previous year and assessment year from 1 Apr 2026, how returns, advance tax, TDS and assessments are labelled, and how FY 2025-26 income is handled.
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TaxWhy angel tax under section 56(2)(viib) ended from AY 2025-26, which old share issues to foreign investors are still exposed, and the FEMA, Companies Act and income tax rules that still apply.
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TaxAdvance tax for companies in India: the four due dates, the INR 10,000 threshold, section 405 computation, interest under sections 424 and 425 (old 234B and 234C), online payment and a cost plus example.
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TaxThe history of India's equalisation levy, the end of the 2 percent e commerce levy on 1 Aug 2024 and the 6 percent advertising levy on 1 Apr 2025, and the income tax, withholding and GST rules that now apply.
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TaxHow the India Canada DTAA taxes a Canadian parent and its Indian subsidiary: dividend, interest and royalty caps, fees for included services, the related enterprise service PE, capital gains, the MLI and the papers.
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TaxHow the India Australia DTAA taxes an Australian parent and its Indian subsidiary: 15 percent dividends and interest, the royalty bands, management fees, the 183 day service PE, section 11J and ECTA.
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TaxWhen a foreign company is taxable in India: business connection under section 9 of the Income Tax Act, 2025, the INR 2 crore and 3 lakh user SEP tests, agents, treaty PE override, digital businesses and a decision table.
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TaxThe rates, holding period, withholding, treaty exemptions for Mauritius, Singapore and Netherlands sellers, buyer side fair value rules and FEMA reporting when a non resident sells unlisted Indian shares.
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TaxWhat Union Budget 2026 and the Finance Act, 2026 changed for foreign owned Indian companies and non residents: MAT, buy back tax, withholding, transfer pricing, new exemptions, customs, GST and FEMA.
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TaxHow India's thin capitalisation rule works for Indian subsidiaries: section 94B and section 177, the INR 1 crore trigger, the 30 percent of EBITDA cap, guarantees, exclusions, parent ECBs and the carry forward.
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TaxCase note on AAR v Tiger Global International II Holdings (2026 INSC 60): the facts, the order, grandfathering under Article 13(3A), TRCs, GAAR and what Mauritius and Singapore holding structures should do now.
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TaxHow India decides the tax residency of a foreign employee: the 182 day and 60 plus 365 day tests, not ordinarily resident status, salary for work in India, the 90 day and treaty short stay exemptions, and the papers.
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TaxHow the India France DTAA taxes a French parent and its Indian subsidiary: the 10 percent rates, the MFN clause after Nestle SA, technical fees, PE, the 10 percent share rule, the MLI and Form 41.
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TaxHow an Indian subsidiary buys back shares from its foreign parent under section 68, prices the buyback under FEMA, files FC-TRS, and withholds tax now that buybacks are capital gains again.
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TaxCase note on AO v Nestle SA (2023 INSC 928): why MFN clauses in India's treaties need a notification, what Switzerland, the Netherlands and France did next, and the dividend rates that apply today.
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TaxHow the India Japan DTAA taxes a Japanese parent and its Indian subsidiary: the 10 percent rates, the wide technical fee definition, JBIC and NEXI interest, PE, capital gains, the MLI and Form 41.
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TaxHow Form 27Q works for TDS on payments to non residents, what goes into it, the 31 July to 31 May due dates, Form 131, corrections, late fee and penalty, and the switch to Form 144 under the Income Tax Act, 2025.
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