The legal basis
A GRCTC is one of the core activities a Finance Company or Finance Unit may carry on under regulation 5 of the IFSCA (Finance Company) Regulations, 2021. IFSCA's circular F. No. IFSCA/24/2024-Banking-FC/01 of 4 April 2025 sets the framework. It replaced the earlier framework of 25 June 2021 and came into force on issue. Existing GRCTCs had six months to meet the new requirements.
The applicant must be a company, or a branch of a company incorporated in India or outside India (clause 5). A company is registered as a Finance Company. A branch is registered as a Finance Unit.
Conditions for registration
At the time of applying, the applicant must (clause 3):
- have or undertake to set up adequate office space, equipment and communications in the IFSC;
- undertake to employ at least five qualified personnel based in the IFSC, including the Head of Treasury and the Compliance Officer, before operations start;
- show that it can meet the owned fund of USD 0.2 million, to be kept at all times (a Finance Unit may keep it at parent level) (clause 6);
- have a parent from a jurisdiction not identified by FATF as a high-risk jurisdiction subject to a call for action;
- satisfy the fit and proper criteria for the applicant, its key managerial personnel and its controllers; and
- not have been refused registration by IFSCA in the previous year.
The application is filed on IFSCA's Single Window IT System with a list of service recipients. IFSCA may grant provisional registration first. Business may start only after the certificate of registration, and the unit must hold a valid Letter of Approval under the Special Economic Zones Act, 2005. Operations must start within six months of registration. An extension of up to three months may be sought at least two months before the deadline.
Fees under clause 18 are USD 1,000 on application, USD 12,500 on registration and USD 25,000 a year.
Who it may serve
A GRCTC may act for its group entities, the group entities of its parent and the branches of either. They may be resident in India or outside India (clause 12). "Group entities" is defined widely: subsidiary, joint venture, associate and related-party relationships under the accounting standards, a common brand name, or an equity investment of 20% or more. Each service recipient must be registered with a competent body in its home jurisdiction. Dealings with recipients resident in India must comply with the Foreign Exchange Management Act, 1999. A GRCTC is not a route to serve third parties outside the group.
What it may do
Clause 13, read with Annex II, permits:
- raising equity and borrowing, including inter-company deposits;
- credit arrangements: lending, credit guarantees and performance bonds;
- investing in financial instruments issued in or outside the IFSC;
- OTC and exchange-traded derivatives, to hedge its own or recipients' risk or to take positions, under a board-approved policy;
- foreign exchange in currencies IFSCA specifies;
- factoring and forfaiting, but only after separate registration as a factor;
- acting as a re-invoicing centre, without taking physical possession of goods, and with a service recipient as a party to each transaction;
- liquidity management, including pooling, netting and cash concentration. The header or master account for pooling must be held with an IBU or an IFSC Banking Company;
- managing relationships with banks and rating agencies, treasury accounting and covenant testing;
- managing recipients' insurance and pension obligations;
- advice on financial and risk management and on funding and capital markets; and
- acting as a holding company.
In the IFSC, transactions must be in a specified foreign currency. Outside the IFSC, other currencies may be used. A GRCTC may also open a Special Non-resident Rupee account with an authorised dealer in India for business outside the IFSC.
Governance and why groups consider it
The board must approve a corporate governance policy, a risk management policy and a policy for permissible activities, with approval limits and audit arrangements. A change in control of 20% or more of a Finance Company needs IFSCA's prior approval. For a Finance Unit, a change at the parent must be notified within 15 days. The IFSCA AML, CFT and KYC Guidelines, 2022 apply to the extent relevant.
Indian multinationals can centralise their offshore treasury in India. Foreign groups can run an Asian treasury hub. Three other regimes bear on the case:
- Company law. On 3 November 2025 MCA extended to IFSCA-registered finance companies, including GRCTCs, a relief from section 186 of the Companies Act, 2013 on loans and investments. See Finance companies.
- Tax. The unit may qualify for the section 147 deduction. Intra-group pricing must be documented. See Section 147 and Transfer pricing.
- Exchange control for lending to, or borrowing from, Indian group companies. See Lending to India.