FDIFEMATaxDPDPASectoral Approvals
AMLEGALS / Market Entry to India
India Market Entry Strategy & Services

The legal architecture that lets India become a market, not a memo.

The decision to enter India is commercial. The way it is executed is legal. Form of entity, FDI route, tax position, sectoral licence, data protection posture and contract architecture — each is a constraint on the next. We sequence them so the business that goes live on Day-1 is the same one that survives Year-5.

India is a tightly regulated, statute-led economy. The cost of a wrong structure is paid every quarter — in tax, in FEMA penalties, in DPDPA exposure, in deal frictions. The cost of the right structure is paid once.
10
Pan-India offices coordinating sector, state and capital approvals end to end
TCL
Technical, Commercial and Legal lens applied to every entry decision
5
Connected disciplines: entity, FDI/FEMA, tax, sectoral licences and operations counsel
The entry stack

Five disciplines. One firm holding the pen.

The entity decides the FDI route. The FDI route shapes the cap table. The cap table drives transfer pricing. Transfer pricing constrains the contract architecture. The contract architecture is what India’s regulators and counterparts actually read. We do not parcel these into silos. We write them as one document set.

The AMLEGALS method

From the first conversation to the first invoice.

Six stages. Each hands clean inputs to the next. Activity mapping decides form. Form decides FDI route. FDI route shapes tax and transfer pricing. Tax and pricing shape contracts. Contracts and policies stand up DPDPA, employment, IP and dispute resolution. Nothing is retrofitted.

01

Activity & Sector Mapping

Identify the precise activities the India entity will perform, map them to the FDI policy, the FEMA NDI Rules and applicable sectoral regulators, and read each activity through the TCL Framework.

02

Form of Entity Selection

Choose between Wholly-Owned Subsidiary, LLP, Branch Office, Liaison Office or Project Office based on revenue model, IP residency, capital plan, repatriation horizon and sector caps.

03

Incorporation & Registrations

Execute SPICe+ filings, obtain PAN, TAN, GST, IEC, Shops & Establishment, Professional Tax, and open the AD Bank current account through to first capital infusion.

04

FDI Filings & Reporting

Complete FCGPR within 30 days of allotment, ensure FCTRS for secondary transfers, document pricing guideline compliance, and report downstream investments and beneficial ownership.

05

Tax & Transfer Pricing Architecture

Lay the corporate tax position, transfer pricing methodology and documentation, GST architecture for inbound and outbound services, and Equalisation Levy / SEP read.

06

Day-1 Operating Architecture

Stand up the contract templates (MSA, SOW, NDA, employment, IP assignment), Privacy Notice and DPDPA consent flows, POSH and labour compliance, and the dispute resolution clause architecture.

The TCL Framework

The Technical, the Commercial and the Legal seams of India entry have to hold under a regulator’s reading.

A tax position that is not technically defensible is theatre. A contract that does not reflect the commercial flow does not survive the first audit. A DPDPA notice that is not engineered into the product cannot be enforced. Our framework reads every entry decision under all three lenses, simultaneously.

  • Technical: data residency, IP residency, system architecture, integrations
  • Commercial: invoicing, transfer pricing, repatriation route, exit mechanics
  • Legal: Companies Act, FEMA, Income-tax Act, GST, DPDPA, sectoral statutes
  • One sequence, three lenses, no internal contradictions
The statutory clocks that govern India entry
Every entry plan is read against these dates, ceilings and statutes.
Each becomes a constraint on the structure. We design to them, not around them.
PN 3
Press Note 3 (2020) land-border vetting
Any investor from a country sharing a land border with India requires prior Government approval. A diligence variable for every cap table.
DPIIT
250 Cr
DPDPA penalty ceiling
Maximum penalty per breach under the DPDPA, 2023. Day-1 DPDPA architecture is no longer optional for new entrants.
DPDPA 2023
30 d
FCGPR reporting window
Form FCGPR must be filed with RBI within 30 days of allotment of shares to a non-resident. Late filing carries compounding exposure.
FEMA NDI Rules 2019
SEC 92
Transfer Pricing
Section 92 of the Income-tax Act, 1961 governs the arm’s length test on every cross-border intra-group transaction. Documentation cannot be retrofitted.
Income-tax Act
Answers

What founders, GCs and boards ask before they engage us.

Short, direct, on the record.

01What is the right form of entity to enter India?

It depends on the activity, capital plan, repatriation horizon and sector. A wholly-owned subsidiary (Private Limited under the Companies Act, 2013) is the default for revenue operations. A Branch Office or Project Office under the Foreign Exchange Management (Establishment in India of a Branch Office or a Liaison Office or a Project Office or any Other Place of Business) Regulations, 2016 is suited for specific approved activities. A Liaison Office cannot generate revenue. An LLP is now FDI-eligible under the automatic route for sectors permitting 100% FDI. We do not start with form; we start with sector, activity, IP residency and repatriation, and the form is the output.

02Is India under the automatic route for our sector or do we need government approval?

The Consolidated FDI Policy and the FEMA Non-Debt Instruments Rules, 2019 govern this read. Most manufacturing, IT/ITES, B2B SaaS and many service sectors are under the 100% automatic route. Multi-brand retail, defence beyond stated caps, satellites, print media and certain financial services require Government approval through DPIIT and the administrative ministry. Press Note 3 (2020) adds a prior approval requirement for any investor from a country sharing a land border with India — a deal variable for every cap table, not just direct shareholders.

03How long does it take to set up and start invoicing in India?

A clean Private Limited incorporation through SPICe+ can complete in 10 to 15 working days post documentation. PAN, TAN, GST registration, IEC and a current account add another 2 to 4 weeks. Where Branch or Project Office route applies, RBI approval through the AD Bank can take 6 to 10 weeks. A defensible plan adds time for FCGPR reporting, transfer pricing documentation, statutory auditor appointment and DPDPA contract retrofit before the first revenue invoice is raised.

04How does Indian tax structuring affect parent-level outcomes?

Three layers govern the read: the India Income-tax Act, 1961 (including transfer pricing under Section 92 and the Place of Effective Management test for residency), the applicable Double Taxation Avoidance Agreement, and the Goods and Services Tax regime for cross-border services. Equalisation Levy, Significant Economic Presence and the digital tax framework are live considerations for digital businesses. The cost of getting structuring wrong is paid at every repatriation — dividend, royalty, fee for technical services, and exit. The architecture has to be decided before the first invoice, not after the first notice.

05Does the DPDPA, 2023 affect a new entrant on Day-1?

Yes. The Digital Personal Data Protection Act, 2023 and the DPDP Rules, 2025 apply to any business processing the personal data of data principals in India, including employee data, customer data and prospect data. The penalty ceiling is INR 250 crore per breach. A new entrant must publish a Privacy Notice in English and the Eighth Schedule languages, obtain free, specific, informed, unconditional, unambiguous consent with clear affirmative action, and ensure data fiduciary obligations are operational from go-live. Building this in at Day-1 is cheaper than retrofitting at scale.

06What does AMLEGALS do that a typical company secretary or accounting firm does not?

A company secretary files. An accountant computes. AMLEGALS engineers the legal architecture that those filings and computations sit on. We read each market-entry decision through the TCL Framework™ — the Technical seam (data, IP, systems), the Commercial seam (revenue, pricing, transfer pricing) and the Legal seam (contract, regulation, disclosure) — and write the structure that survives DPDPA enforcement, FEMA scrutiny, GST audit and a future M&A or IPO data room.

Intelligence

Perspectives that shape India entry decisions.

Doctrine

India does not reward the elegant structure. It rewards the defensible one.

An entry plan that wins a slide deck rarely survives a regulator. The structures that hold are not the cleverest — they are the ones that read straight under FEMA, ICDR, DPDPA and Section 92 of the Income-tax Act simultaneously.

Read the perspective
DPDPA

Day-1 DPDPA, or Year-5 retrofit. Pick one.

The cost of building DPDPA into the product on Day-1 is small. The cost of retrofitting it across thousands of customers, vendors and employees after a notice is not. New entrants choose the side of this trade once.

Read the perspective
FDI

Press Note 3 is a cap-table variable, not a footnote.

The land-border rule does not just touch direct foreign shareholders. It reaches through holding structures, downstream vehicles and beneficial ownership. Treating it as a footnote is how Indian transactions get stuck.

Read the perspective
Engage AMLEGALS

Bring us the decision while it is still a decision — not a deadline.

The earliest mandate is the most valuable mandate. Sector, form, route and jurisdiction are decided long before incorporation.

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