Transfer pricing documentation for captive GCCs requires accurate functional characterisation, complete cost bases, and function-specific benchmarking.
Captive GCC transfer pricing depends on arm's length remuneration supported by an evidence-based functional analysis, a complete and consistently applied cost base, and function-specific benchmarking. The analysis should establish the GCC's functions, assets, risks, decision-making authority and intellectual-property role. Share-based employee costs, pass-through expenditure, foreign-exchange items, depreciation and facility costs require documented treatment. Local-file documentation, accountant reporting, applicable master-file and country-by-country reporting, and intercompany agreements must align with actual operations. Safe harbour rules and advance pricing agreements may provide pricing certainty for eligible GCCs. (AI Summary)

Foreign-owned subsidiary closure: strike-off suits inactive debt-free companies, while voluntary liquidation addresses asset distribution, creditors and final dissolution.
Strike-off is appropriate for an inactive or non-commenced company with liabilities discharged, filings updated and no material disputes, subject to shareholder approval, prescribed filings and public notice. Voluntary liquidation is appropriate where assets, surplus cash, contracts, creditors or claims require an orderly process, beginning with a solvency declaration and resulting in asset realisation, stakeholder distribution and final dissolution. Foreign exchange reporting, repatriation requirements, tax matters, GST, employee dues, local registrations and bank-account closure must be completed under either route. (AI Summary)

Foreign director appointments require DIN, resident-director compliance, filings, KYC, tax withholding, and appropriate visa arrangements in Indian companies.
Foreign nationals may serve as directors of Indian companies, but every company must maintain at least one director satisfying the resident-director requirement. Appointment requires a Director Identification Number, Digital Signature Certificate, legalised identity and address documents, consent, a non-disqualification declaration, prescribed appointment filings and interest disclosures. Foreign directors must comply with periodic KYC, attendance requirements, directorship limits and disqualification rules. Non-resident director remuneration generally requires Indian tax withholding and remittance compliance, while executive roles performed from India generally require employment-visa compliance. (AI Summary)