Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Revised capital adequacy (net worth) and new liquid net worth requirements under the Merchant Bankers Regulations apply from 3 January 2026, with existing merchant bankers required to meet phased thresholds by 2 January 2027 and 2 January 2028, intimate their intended Category I/II by 2 January 2027 with a CA-certified net worth (including liquid net worth) certificate, and face automatic down-categorisation to Category II or a bar on fresh permitted activities for non-compliance. "Liquid net worth" is prescribed as unencumbered liquid assets subject to specified haircuts, and total underwriting obligations are capped at 20 times liquid net worth (existing entities to comply by 2 January 2028), with half-yearly CA certifications. Mandatory NISM certifications, separation of the compliance officer, five-year experience for the principal officer, prohibition on outsourcing core activities (legacy arrangements to end by 3 April 2026), minimum revenue thresholds with cancellation exposure from 1 April 2029, marketing-only conflict disclosures, and ring-fenced SBU conditions for non-regulated activities are specified with defined timelines and reporting.
Revised capital adequacy (net worth) and new liquid net worth requirements under the Merchant Bankers Regulations apply from 3 January 2026, with existing merchant bankers required to meet phased thresholds by 2 January 2027 and 2 January 2028, intimate their intended Category I/II by 2 January 2027 with a CA-certified net worth (including liquid net worth) certificate, and face automatic down-categorisation to Category II or a bar on fresh permitted activities for non-compliance. "Liquid net worth" is prescribed as unencumbered liquid assets subject to specified haircuts, and total underwriting obligations are capped at 20 times liquid net worth (existing entities to comply by 2 January 2028), with half-yearly CA certifications. Mandatory NISM certifications, separation of the compliance officer, five-year experience for the principal officer, prohibition on outsourcing core activities (legacy arrangements to end by 3 April 2026), minimum revenue thresholds with cancellation exposure from 1 April 2029, marketing-only conflict disclosures, and ring-fenced SBU conditions for non-regulated activities are specified with defined timelines and reporting.
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