Operate: the captive centre

Setting Up a Global Capability Centre in India for a Singapore Group: Models, Pricing, Tax and Risk

By Abhishek Jaiin, Chartered Accountant (ICAI membership no. 544646), AU Corporate · Last updated 21 October 2026

Short answer

A Global Capability Centre (GCC) is a captive team in India that does technology, finance, analytics or operations work for the Singapore group, and the usual form is an Indian subsidiary paid cost plus a mark-up. The legal work is the same as for any subsidiary, but three issues decide success: pricing that survives Indian and Singapore transfer pricing review, export-of-services treatment for GST, and keeping Singapore managers from creating a permanent establishment. Regulated Singapore financial groups also need MAS outsourcing controls.

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Key facts

ModelsCaptive subsidiary; build-operate-transfer with a partner; hybrid or shared service with a partner running part of the operation
PricingCost plus a mark-up from benchmarking, usually under a services agreement with the Singapore entity
GSTServices supplied to a recipient outside India, paid in convertible foreign exchange, can be zero-rated as exports if the conditions are met
PE riskSingapore staff who direct or conclude contracts in India can create a taxable presence
RegulationMAS outsourcing expectations for financial institutions; Indian sector rules if the work touches Indian customers
TalentLarge technical hiring pools in several Indian cities; wage inflation and attrition need budgeting

The three models

ModelHow it worksBest forWatch for
Captive subsidiaryYou own and run the Indian entityCore functions, long-term, high controlSet-up time and management bandwidth
Build-operate-transferA partner builds and runs the centre, then transfers it to youSpeed and low initial riskTransfer terms, tax on the transfer, knowledge ownership
HybridYou hold the entity; a partner runs part of operationsMixed models while you build capabilitySplit responsibilities; data access

Pricing the centre

  • The Indian entity is normally characterised as a low-risk service provider paid cost plus a mark-up.
  • The mark-up comes from a benchmarking study of independent companies with similar functions, and is reviewed each year.
  • IRAS accepts a published mark-up for routine support services on the Singapore side; India still wants its own benchmarking. See transfer pricing.
  • Document the service scope, hours and cost base, and keep time and cost records for audit.

Indian GST on exports of services

A supply of services by the Indian entity to the Singapore group can be zero-rated as an export if the recipient is outside India, the service is delivered there, payment is in convertible foreign exchange and the supplier and recipient are not merely establishments of a distinct person. The last point matters for a branch. A subsidiary is a separate person, so the structure helps. File the right documents and claim input credit refunds.

Avoiding a permanent establishment

  • Keep contract-making authority with the Indian entity for Indian customers and with the Singapore entity for Singapore customers.
  • Do not let Singapore staff run the Indian team day to day from India beyond defined visit days.
  • Keep intercompany agreements, invoices and board minutes consistent with the stated risk profile.
  • Review the thresholds in the tax treaty guide: services staff above 90 days (30 days for services to an associated enterprise) are a risk.

Controls for regulated groups

  • Document the outsourcing arrangement, the risk assessment and the exit plan for MAS-regulated entities.
  • Make sure the Indian entity can give your auditors and regulators access to records and premises.
  • Test business continuity from the Indian site.
  • Align data security with the data protection programme. See PDPA and DPDP.

A practical start

  1. Define scope: functions, headcount in years one to three, and the target cost.
  2. Choose the city, the premises model (managed office, coworking or own lease) and the hiring plan.
  3. Form the subsidiary and sign the services agreement before work starts.
  4. Hire leaders first, then the team, with a knowledge transfer plan from Singapore.
  5. Review the pricing and the tax position after the first year.

Official sources

Check the rules at the primary sources: Income Tax Department (India), Reserve Bank of India, Ministry of Corporate Affairs, IRAS, ACRA and the Singapore Academy of Law (apostilles).

Frequently asked questions

What is a Global Capability Centre?

A captive team in India that performs technology, finance, analytics or operations work for the parent group. The usual form is an Indian subsidiary paid cost plus a mark-up.

How is a GCC priced for tax?

Normally cost plus a mark-up from a benchmarking study, under a services agreement with the Singapore entity, and reviewed each year.

Are GCC services to Singapore exempt from GST in India?

They can be zero-rated as exports of services if the recipient is outside India, payment is in convertible foreign exchange and the other conditions are met.

Does a GCC create a permanent establishment for the Singapore parent?

Not by itself if the Indian entity is a separate low-risk provider, but Singapore staff directing the work or concluding contracts in India can create one.

Does MAS regulate a captive centre in India?

MAS regulates the Singapore financial institution, and expects outsourcing controls over work done by a group company in India.

Should we use build-operate-transfer?

It reduces early risk and time, but check the transfer terms, tax on the transfer and who owns the know-how.

See all 143 FAQs →Plain answers on incorporation, FEMA, tax, hiring and exit.

Sources

← Back to the complete guide

Last updated 21 October 2026. General information only, not legal or tax advice. Indian and Singapore rules change often; confirm current requirements before acting.

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