CA K Sanjay BhargavChartered Accountant
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Taxation of a GCC or captive unit in India

CA K Sanjay Bhargav, Chartered Accountant, Bengaluru

Membership No. 250054 · DISA (ICAI)

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Short answer: a captive has one customer, and that customer owns it. There is no market price to point at and no negotiated return, so five separate tax questions all trace back to the same structural fact — transfer pricing, the parent's permanent establishment exposure, GST, secondment of expatriates, and ESOP recharge.

Why this entity is different

An ordinary company sells to strangers. Its prices are evidence of what its services are worth, and the tax system can largely take them as given.

A Global Capability Centre does not. It typically:

  • earns all or nearly all of its revenue from its parent or affiliates;
  • is remunerated on cost plus a markup fixed by agreement;
  • takes no market risk and holds no customer relationships of its own; and
  • is staffed partly by people the parent sent.

Every one of those is a fact pattern the department examines closely, and none of them is an accusation. They are simply what a captive is. The work is demonstrating that the arrangement is what it says it is, and that it has been priced and documented consistently.

The five questions

QuestionWhose tax
1Is the markup at arm's length, and is it documented?The captive's
2Does the parent have a permanent establishment in India?The parent's
3Is the service to the parent an export, and is credit recoverable?The captive's
4Are seconded expatriates a supply of manpower for GST?The captive's, under reverse charge
5Is the ESOP recharge deductible, priced and correctly withheld on?The captive's

Question 2 is the one that should worry a group most, because it is the only one where the exposure sits with the parent and is measured on profits attributable to India rather than on an adjustment to a markup.

1. Transfer pricing, and the 2026 reset

Arm's length pricing sits at s.161 of the Income-tax Act, 2025 (the old s.92), with reference to the Transfer Pricing Officer at s.166 (the old s.92CA).

For a cost-plus captive the live questions are the markup percentage, what sits inside the cost base it is applied to, and the comparables used to support it.

What changed on 1 April 2026 is the alternative to all of that. The safe harbour regime was substantially rebuilt: IT and ITeS merged into one category at a unified 15.5% margin, with the eligibility threshold raised from ₹300 crore to ₹2,000 crore, and a five-year block in which the revenue threshold is tested only in the first year.

That is a different proposition from the old regime, and a GCC that ruled safe harbour out years ago — on the old margins, or because it was above the old threshold — is very likely working from a conclusion that no longer holds. See the new safe harbour rules.

2. The parent's permanent establishment

The captive pays its own tax on its own markup. A permanent establishment finding does something different: it makes the parent taxable in India on the profits attributable to that establishment.

The exposure is a function of how the relationship actually operates, not of what the intercompany agreement recites — premises at the parent's disposal, personnel rendering services in India, and authority to conclude contracts are all tested against conduct. See permanent establishment risk for the foreign parent.

3. GST — and the condition that catches captives

The service to the parent looks like a textbook export: overseas recipient, foreign exchange, work done in India. Whether it is one turns on a condition that has nothing to do with any of that.

Export treatment is denied where supplier and recipient are merely two establishments of the same person. So:

  • an Indian subsidiary supplying its foreign parent is two persons and can export;
  • an Indian branch or project office supplying its own head office is one person and cannot.

For a captive, this single point often decides the entire GST position — and it was settled years earlier, when someone chose the entity form for reasons that had nothing to do with tax. See the five conditions.

4. Seconded expatriates

Where the parent sends people to work in India and recovers their cost, the question is whether that recovery is a supply of manpower taxable in the Indian entity's hands under reverse charge.

The Supreme Court held that it was on the facts before it in Northern Operating Systems — but framed the decision on those facts, and CBIC has since instructed that it must not be applied mechanically to every secondment. Later High Court decisions have gone the other way where the facts differed.

The answer turns on who actually employs and controls the individual, how the cost is recovered, and whether anything beyond salary is being recharged. See secondment and the expat GST question.

5. ESOP recharge

Where employees of the Indian entity hold options over the parent's stock and the parent recharges the cost, three questions arrive together:

  • Deductibility in the captive's computation;
  • Transfer pricing, because the recharge is an international transaction in its own right; and
  • Withholding on the payment out.

They are usually examined separately and are better looked at together — a recharge that fails one tends to fail the others for the same underlying reason. See ESOP recharge from a foreign parent.

What holds it all together

One observation is worth more than the five sections above: these questions are decided by the same set of facts.

Who controls the expatriates bears on both the secondment analysis and the PE analysis. Whether the entity is a subsidiary or a branch decides the GST answer and shapes the PE one. What sits in the cost base drives the markup and the ESOP recharge. The intercompany agreement is read in all five.

That is why answering them one at a time, by different advisers, in different years is how groups end up with positions that contradict each other — and a contradiction between two of your own filings is the most expensive thing in this area, because it does the department's work for it.

This is a working reference, not the statute. For anything you are relying on, confirm the section and rule text directly.

Frequently asked questions

Why does a captive attract so much more scrutiny than an ordinary company?

Because it has one customer and that customer owns it. Nearly every rupee of its revenue comes from a related party, so there is no market price to point at and the return it earns is set by agreement rather than by negotiation. Everything the department examines — the markup, the cost base, whether the parent has a presence in India, whether expatriates are employees or a supply of manpower — follows from that single structural fact.

What changed for safe harbour from 1 April 2026?

A great deal. IT and ITeS were merged into a single Information Technology Services category with a unified margin of 15.5%, replacing the previous category-specific range, and the eligibility threshold rose from ₹300 crore to ₹2,000 crore of transaction value. The block period for IT services is five years, with the revenue threshold tested only in the first year. A GCC that concluded years ago that safe harbour was not for it should re-run that conclusion, because both the margin and the threshold moved substantially in its favour.

Can our foreign parent end up taxable in India because of us?

It can, and the risk is a function of how the relationship actually operates rather than what the agreement says. A permanent establishment can arise where the parent has a fixed place at its disposal in India, where its personnel render services here beyond a threshold period, or where someone in India habitually concludes contracts on its behalf. Where a PE is found, the profits attributable to it are taxable in India in the parent's hands, which is a materially larger problem than an adjustment to the captive's markup.

Are our seconded expatriates a GST problem?

Possibly, and the position is genuinely fact-dependent. The Supreme Court in Northern Operating Systems held a particular secondment arrangement to be a taxable supply of manpower, but framed the decision on its own facts, and CBIC has instructed that it should not be applied mechanically. Later High Court decisions have gone the other way on different facts. What determines the answer is who actually employs and controls the individual, how the cost is recovered, and whether anything beyond salary is being recharged.

Is our parent's ESOP cost deductible when it recharges us?

It is capable of being deductible where the recharge represents a real cost borne for employees who work for the Indian entity, and where it is supported by an agreement and evidence of actual payment. It is also an international transaction, so it has to survive transfer pricing scrutiny in its own right, and there is a withholding question on the payment out. The three are usually looked at separately and should be looked at together, because a recharge that fails one of them tends to fail the others for the same reason.

Running a GCC or captive in Bengaluru?

Send the intercompany agreement, the cost base and markup, and the expatriate arrangements. The transfer pricing position, the parent's exposure and the GST treatment are worked through together, because they are decided by the same set of facts.

Related service: GCC & Captive Units