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Global capability centres

GCC set-up roadmap: location choice to go-live

A captive centre moves from feasibility to go-live in ten broad steps. Only a few have deadlines fixed by rule, chiefly share allotment, FC-GPR reporting and commencement of business. The order matters most around the lease, incentive registration and transfer pricing.

60 daysTo allot shares after receiving the foreign remittance
30 daysTo file Form FC-GPR after issuing shares to the parent
180 daysTo declare commencement of business after incorporation
13 May 2027DPDP core duties (notice, consent, breach reporting) apply
Facts as of 1 October 20267 sources citedHow we keep this current

Scope of this roadmap

This roadmap is sized for a captive centre of 100–500 seats, owned through a wholly owned private limited company in a sector open to 100% FDI under the automatic route. Timings are shown only where a rule fixes them. Everything else depends on the authority, the case and the applicant.

IMC’s stated timeline for a capability centre is “typically operational in 90 to 120 days, subject to approvals”. Treat any timeline as an estimate until the approvals in your case are known.

The ten steps

StepWhat happensFixed timeAuthority
1. Feasibility and locationBusiness case, operating model, city and state screening. Incentives often pay more outside the main metrosNoneGroup; state IT or industries department
2. Choose the vehicleUsually a private limited subsidiary; check the land-border ruleNoneGroup; FIF/NSWS if the government route applies
3. IncorporateSPICe+ with AGILE-PRO-S: incorporation, DIN, PAN and TAN, with GST, EPFO and ESIC registrationNoneMCA (Central Registration Centre)
4. Bank, capital and FC-GPRReceive share capital through an AD bank, allot shares at not less than fair value, report the issueAllot within 60 days of receipt; FC-GPR within 30 days of issueAD bank; RBI FIRMS portal
5. OfficeManaged space or lease; decide on STPI or SEZ registration. Confirm stamp duty relief before signing the leaseNoneLandlord; STPI or SEZ authority
6. State incentive registrationRegister under the state GCC or IT policy before claimingSet by each policyState IT or industries department
7. Hire leaders and staffLabour Code registrations, appointment letters, payroll, EPF and ESICNoneState labour department; EPFO; ESIC
8. Inter-company agreement and transfer pricingServices agreement with the parent; choose the 15.5% safe harbour (five-year option) or seek an APANoneCBDT / Income Tax Department
9. IT, security and data protectionSystems, security safeguards and a DPDP compliance planDPDP core duties from 13 May 2027MeitY; Data Protection Board
10. Go-live and claimsStart operations, declare commencement of business, begin incentive claimsCommencement within 180 days of incorporationMCA; state department

Incorporation in more detail

The company-law steps follow the general set-up roadmap:

  1. Apostille or legalise the parent’s constitutional documents, board resolution and the IDs of foreign subscribers and directors.
  2. Obtain a digital signature certificate for at least one proposed director; DINs are applied for within SPICe+.
  3. Reserve the name through RUN or SPICe+.
  4. File SPICe+ with the MoA, AoA and AGILE. One filing covers incorporation, DIN, PAN and TAN, and the linked form can also obtain GST, EPFO and ESIC registrations. Foreign subscribers attach a signed physical MoA and AoA.
  5. Receive the certificate of incorporation with CIN, PAN and TAN.

The company needs at least two shareholders and two directors, one of whom meets the 182-day residence test.

FEMA steps and deadlines

FilingDeadlineWhere
Share allotmentWithin 60 days of receiving funds; otherwise refund within the next 15 daysCompany and AD bank
PricingNot below fair value set by a SEBI-registered merchant banker or a CA; valuation under 90 days oldValuer
FC-GPRWithin 30 days of issueRBI FIRMS portal
FLA returnOn or before 15 July each yearRBI
Land-border prior reportBefore the money is remittedFIF/NSWS portal

See the FEMA compliance calendar for recurring filings.

Registrations before the first hire

  • Shops and establishments and professional tax, under state law.
  • EPFO and ESIC, which SPICe+ can trigger. The EPF Scheme, 2026 was notified on 29 June 2026 under the Code on Social Security.
  • Labour Code registrations. The four codes apply from 21 November 2025, with a single registration, licence and return replacing multiple filings. State rules also apply.
  • GST. Low-risk applicants can opt for automated registration within three working days. Since the Finance Act 2026 removed the special place-of-supply rule for intermediary services, services to the parent follow the general rule and can qualify as exports.
  • IEC from DGFT where the centre imports equipment or exports.
  • Employment visas for any expatriate leaders, through the Indian mission; these are for highly skilled professionals, not routine roles.

Points where order matters

  • Lease before incentive check. Several state GCC policies tie stamp duty relief to IT parks, SEZs and STPIs. Confirm eligibility before signing.
  • Incentive registration before claims. Maharashtra issues a Registration Certificate and requires units to stay operational for at least 10 years. Tamil Nadu’s scheme admits up to 50 GCCs in its window to 31 March 2027.
  • Transfer pricing before the first invoice. The inter-company agreement fixes how the centre is paid. Decide between the safe harbour and an APA before invoicing begins; see tax and transfer pricing.
  • Hiring before ELI windows close. The employment-linked incentive covers jobs created up to 31 July 2027; see people and hiring.
  • Data protection before go-live. Consent Managers register from 13 November 2026 and core duties apply from 13 May 2027. Breaches of the security safeguards duty carry penalties of up to ₹250 crore.

After go-live

Ongoing compliance includes the annual FLA return, the transfer-pricing accountant’s report (still required; non-furnishing now attracts a fee rather than a penalty under the Finance Act 2026), annual financial statements and returns, director KYC and beneficial-ownership filings. The sources do not give dates for the last group; confirm them with the authority.

What to check next

  • Confirm the land-border position of every shareholder and beneficial owner before step 2.
  • Check whether the chosen building qualifies for stamp duty relief under the state policy before signing.
  • Diary the 60-day allotment and 30-day FC-GPR deadlines from the date funds arrive.
  • Register under the state incentive policy before incurring costs you intend to claim.
  • Build a DPDP plan against the 13 November 2026 and 13 May 2027 dates.

Planning a capability centre in India?

IMC sets up and runs GCCs under all three models, typically operational in 90 to 120 days, subject to approvals.

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