GIFT City as a Hub for Centralised Treasury Functions: The GRCTC Framework

Introduction

The Gujarat International Finance Tec-City, commonly known as GIFT City, represents India’s ambitious stride toward establishing itself as a global financial hub. Located in Gandhinagar, Gujarat, GIFT City houses India’s first International Financial Services Centre and operates under a specialized regulatory framework designed to attract multinational corporations and facilitate international financial transactions. At the heart of this ecosystem lies the Global and Regional Corporate Treasury Centre framework, which enables corporations to centralize their treasury operations in a tax-efficient, well-regulated environment. The GRCTC framework has emerged as a strategic tool for multinational corporations seeking to optimize their global treasury functions while benefiting from India’s cost advantages and strategic geographic location.

Understanding the Legal Framework Governing GIFT City

The legal architecture supporting GIFT City’s operations rests on multiple legislative pillars that create a unique regulatory environment. The International Financial Services Centres Authority Act, 2019 [1] established the International Financial Services Centres Authority as the unified regulator for all financial services in International Financial Services Centres across India. This legislation consolidated regulatory powers that were previously distributed among various domestic regulators including the Reserve Bank of India, Securities and Exchange Board of India, Insurance Regulatory and Development Authority of India, and Pension Fund Regulatory and Development Authority.

The IFSCA Act grants the Authority comprehensive powers under Section 12 and Section 13 to develop and regulate financial products, financial services, and financial institutions within IFSCs. These provisions empower IFSCA to create tailored regulatory frameworks that align with international best practices while maintaining appropriate oversight. The establishment of IFSCA as a unified regulator addresses the fundamental challenge of coordinating multiple regulatory authorities, thereby creating a streamlined approval process through a single-window mechanism.

The Special Economic Zones Act, 2005 provides another critical legislative foundation for GIFT City’s operations. Section 18(1) of the SEZ Act specifically empowers the Central Government to establish International Financial Services Centres within designated Special Economic Zones [2]. This provision creates a legal sandbox where both foreign and domestic financial entities can operate under internationally competitive regulatory norms while enjoying certain relaxations compared to the mainstream domestic market. The SEZ framework provides GIFT City with its special status, enabling it to offer duty exemptions, tax holidays, and simplified compliance procedures that make it attractive for global financial operations.

The GRCTC Framework: Regulatory Evolution and Current Structure

The journey toward establishing a robust framework for Global and Regional Corporate Treasury Centres in GIFT City began with the International Financial Services Centres Authority (Finance Company) Regulations, 2021. These regulations, notified on March 25, 2021, established the foundational structure enabling Finance Companies and Finance Units to undertake various permissible activities within IFSCs, including the operation of GRCTCs. The regulations were enacted under the authority vested in IFSCA through Section 28(1) read with Section 12(1) and Section 13(1) of the IFSCA Act, 2019.

Following extensive stakeholder consultation, IFSCA issued the original Framework for undertaking Global/Regional Corporate Treasury Centres Activities by Finance Company/Finance Unit in IFSC on June 25, 2021 [3]. This initial framework outlined the basic requirements for setting up treasury centers and the permissible activities they could undertake. However, as market participants gained experience with the framework and global best practices evolved, the need for revision became apparent.

In September 2024, IFSCA released a consultation paper seeking public feedback on proposed revisions to the GRCTC framework [4]. This consultative approach reflected the Authority’s commitment to creating regulations that genuinely serve market needs while maintaining appropriate oversight. The consultation period extended until October 2, 2024, during which stakeholders provided valuable insights on operational challenges and areas requiring clarification.

The culmination of this consultative process was the issuance of the revised Framework for Finance Company/Finance Unit undertaking the activity of Global/Regional Corporate Treasury Centres on April 4, 2025, through Circular F. No. IFSCA/24/2024-Banking-FC/01 [5]. This updated framework superseded the 2021 circular and introduced significant enhancements aimed at promoting ease of doing business and aligning with international best practices. The revised framework became effective immediately upon issuance, though existing GRCTCs were granted a six-month transition period to comply with additional requirements.

Registration Requirements and Eligibility Criteria Under the GRCTC Framework

The revised GRCTC framework establishes clear eligibility conditions that applicants must satisfy before obtaining registration as a Finance Company or Finance Unit authorized to undertake treasury center activities. These requirements are designed to ensure that only credible entities with adequate resources and governance structures operate within the IFSC ecosystem.

An entity seeking to establish a GRCTC must apply for registration under sub-regulation (4) of regulation 3 of the FC Regulations through the Single Window IT System at https://swit.ifsca.gov.in/. The application process requires the entity to demonstrate possession of or commitment to establish necessary infrastructure in IFSC, including adequate office space, equipment, and communication facilities suitable for undertaking permissible activities.

One of the most significant additions in the revised framework is the mandatory substance requirement. Applicants must undertake to employ at least five qualified personnel based in IFSC to undertake permissible activities, including the Head of Treasury and the Compliance Officer, before commencing operations [5]. This requirement represents a departure from the erstwhile framework, which had no specific mention of minimum personnel requirements for GRCTCs beyond those applicable to finance companies generally. This change ensures that GRCTCs maintain genuine operational presence in GIFT City rather than serving as mere shell entities.

The framework mandates minimum owned fund requirements of USD 0.2 million, which must be maintained at all times. For Finance Units operating as branches, this requirement may be satisfied by maintaining the requisite owned fund at the parent level. The concept of “Owned Fund” is precisely defined as paid-up capital and free reserves, balance in share premium account and capital reserves representing surplus arising out of sale proceeds of assets, excluding reserves created by revaluation of assets, as reduced by accumulated loss balance, book value of intangible assets and deferred revenue expenditure.

Jurisdictional requirements ensure that the parent entity of the applicant must not be from a jurisdiction identified in the public statement of Financial Action Task Force as “High Risk Jurisdiction – subject to call for action.” This provision safeguards the integrity of the IFSC ecosystem by preventing entities from high-risk jurisdictions from establishing operations in GIFT City.

Permissible Activities and Operational Flexibility

The GRCTC framework delineates a wide array of permissible activities that registered entities may undertake, providing significant operational flexibility while maintaining regulatory oversight. These activities encompass the full spectrum of treasury functions that multinational corporations require for effective financial management across jurisdictions.

Capital raising activities are permitted through issuance of equity shares, enabling GRCTCs to maintain appropriate capitalization levels. Borrowing activities, including inter-company deposits, allow GRCTCs to access funding from group entities on terms determined either independently or in consultation with service recipients. Credit arrangements encompass lending activities by whatever name called, provision of credit guarantees, performance bonds, and any other credit facilities that service recipients may require.

The framework permits GRCTCs to transact or invest in financial instruments issued both within and outside IFSC. The term “financial instruments” carries the meaning assigned under Indian Accounting Standard 32, providing clarity on the scope of permissible investments. This broad definition enables GRCTCs to maintain diversified portfolios aligned with their treasury objectives.

Derivative transactions represent a crucial component of treasury operations, and the framework provides detailed guidelines for such activities. GRCTCs may undertake over-the-counter derivative transactions permitted in IFSC with counterparties within and outside IFSC. They may also undertake OTC derivative transactions not permitted in IFSC with counterparties outside IFSC, and exchange-traded derivative transactions on exchanges both within and outside IFSC [5]. All derivative transactions must be undertaken in compliance with a board-approved policy, ensuring appropriate governance and risk management.

Foreign exchange transactions constitute another core treasury function, with the framework permitting transactions in currencies specified by the Authority. The revised framework introduced significant flexibility by allowing operations in any of the Specified Foreign Currencies within IFSC, while permitting transactions outside IFSC in currencies other than Specified Foreign Currencies. Additionally, GRCTCs may now open Special Non-resident Rupee accounts under Schedule 4 of the Foreign Exchange Management (Deposit) Regulations, 2016, with an authorized dealer in India outside IFSC for business-related transactions.

Factoring and forfaiting activities are permitted, though entities must obtain separate registration under the IFSCA (Registration of Factors and Registration of Assignment of Receivables) Regulations, 2024. Importantly, GRCTCs undertaking factoring activities are exempt from paying separate registration and recurring fees for this activity, reducing the compliance burden.

The revised framework explicitly permits GRCTCs to act as re-invoicing centers, addressing a long-standing area of ambiguity. A GRCTC may now facilitate financing the purchase and sale of goods on behalf of service recipients under a Bill-to-Ship-to model, provided the GRCTC does not take physical possession of such goods and one of the parties to each re-invoicing transaction is a service recipient [5]. This clarification enables effective foreign exchange control and liquidity centralization for trading multinationals.

Liquidity management activities encompass pooling of funds, optimizing cash flows, interest payments, working capital and tax payments through netting and cash concentration, confirmation and reconciliation of receipts, processing payments to vendors or suppliers, negotiating payment terms, consolidating and managing payments across the group, managing liquidity and investing surplus funds, and developing pooling mechanisms. For pooling transactions, the header or master account must be maintained with an International Banking Unit or International Banking Centre.

Additional permissible activities include maintaining relationships with financial counterparties such as banks, credit rating agencies, and other financial institutions, managing obligations toward insurance and pension-related commitments, providing advisory services related to financial management and capital market activities, and acting as a holding company for group entities.

Service Recipients and Group Structure Flexibility

The revised GRCTC framework introduces enhanced flexibility regarding service recipients while maintaining appropriate safeguards. A Finance Company or Finance Unit undertaking GRCTC activities may provide services to its Group Entities, Group Entities of its Parent, and branches of such Parent or Group Entities. These Service Recipients may be either persons resident in India or persons resident outside India within the meaning of the Foreign Exchange Management Act, 1999.

The definition of “Group Entities” under the framework is deliberately broad, encompassing arrangements involving entities related through subsidiary-parent relationships as defined in Ind-AS 110 or Accounting Standard 21, joint ventures as defined in Ind-AS 28 or Accounting Standard 27, associates as defined in Ind-AS 28 or Accounting Standard 23, related parties as defined in Ind-AS 24 or Accounting Standard 18, common brand name, or investment in equity shares of twenty percent and above.

This expansive definition enables GRCTCs to serve complex multinational structures effectively. However, the framework imposes certain safeguards to ensure legitimacy. Service Recipients must be registered under applicable law with competent or statutory bodies in their home jurisdictions. GRCTCs must maintain an updated list of Service Recipients and provide such list to IFSCA when called for, ensuring regulatory visibility into the entities being serviced.

Where GRCTCs undertake permissible activities with Service Recipients who are persons resident in India, they must comply with provisions of the Foreign Exchange Management Act, 1999, as applicable. This requirement ensures that cross-border transactions involving Indian residents adhere to foreign exchange regulations, preventing circumvention of FEMA provisions through IFSC structures.

Governance and Compliance Requirements

The GRCTC framework establishes rigorous governance standards ensuring that treasury centers operate with appropriate oversight and risk management mechanisms. These requirements reflect the Authority’s commitment to maintaining high operational standards while avoiding unnecessary regulatory burden.

Every GRCTC must maintain a board-approved corporate governance policy that comprehensively and clearly documents its governance arrangements, including the framework under which its board and senior management function. This policy must address the specific governance challenges associated with treasury operations, which often involve complex financial instruments and cross-border transactions.

Risk management receives particular emphasis in the governance requirements. GRCTCs must maintain a board-approved risk management policy that includes procedures and systems to identify, measure, monitor, and manage the range of risks to which the GRCTC is exposed [5]. Given that treasury operations inherently involve various financial risks including interest rate risk, foreign exchange risk, credit risk, and liquidity risk, this requirement ensures that adequate risk mitigation frameworks are in place.

A board-approved policy for undertaking permissible activities must address the approval process including delegation of powers, financial limits for undertaking permissible activities, procedures for oversight and audit, and any other relevant control mechanisms based on the nature of activities undertaken. This policy ensures that permissible activities are conducted within appropriate parameters and subject to proper authorization.

All governance policies must be periodically reviewed by the board, ensuring they remain relevant as business conditions and regulatory expectations evolve. This requirement prevents governance frameworks from becoming outdated or disconnected from operational realities.

The framework addresses corporate actions that could fundamentally alter a GRCTC’s ownership or control structure. Any mergers, acquisitions, takeovers, or changes in management resulting in change of control of at least twenty percent of total share capital or authority to take business decisions under an agreement require prior approval from IFSCA [5]. For Finance Units, changes in the parent’s ownership structure must comply with registration conditions and be intimated to IFSCA within fifteen days.

GRCTCs must adhere to the IFSCA (Anti Money Laundering, Counter-Terrorist Financing and Know Your Customer) Guidelines, 2022, as amended, and related circulars. However, certain exemptions may apply based on the nature of activities and counterparties, as outlined in relevant IFSCA circulars.

Tax Framework and Incentives

The tax regime applicable to GIFT City entities constitutes one of the most compelling reasons for establishing operations in the IFSC. Section 80LA of the Income Tax Act, 1961, as amended by the Finance Act, 2023, provides the cornerstone of tax benefits available to IFSC units [6].

Under Section 80LA(1A), units of an International Financial Services Centre are eligible for a deduction of one hundred percent of total income for any ten consecutive assessment years, at the option of the assessee, out of fifteen years. The computation of these fifteen years commences from the assessment year relevant to the previous year in which registration under the International Financial Services Centres Authority Act, 2019, was obtained. This deduction applies to income arising from business for which the unit has been approved for setting up in the IFSC within a Special Economic Zone.

The benefit of Section 80LA is not limited to offshore banking units but extends to all eligible IFSC units, including GRCTCs. This provision effectively creates a decade-long tax holiday for qualifying income, significantly reducing the effective tax burden and enhancing returns on treasury operations. Following the ten-year period of complete exemption, units can benefit from reduced tax rates compared to standard corporate tax rates.

The Finance Act, 2023, introduced additional tax benefits specifically relevant to treasury and financial operations. Section 10(4F) exempts income of non-residents by way of royalty on account of lease of aircraft paid by IFSC units eligible for deduction under Section 80LA. Section 10(4G) exempts income received by non-residents from portfolios of securities or financial products managed by portfolio managers in accounts maintained with Offshore Banking Units in IFSCs, to the extent such income accrues or arises outside India and is not deemed to accrue or arise in India.

Section 10(4H) provides exemption for capital gains arising from transfer of equity shares of domestic companies engaged primarily in aircraft leasing business, where both the transferor and transferee are IFSC units [7]. These provisions complement the GRCTC framework by creating a favorable tax environment for various treasury activities.

Notification No. 67/2025 dated June 20, 2025, further enhanced the tax efficiency of IFSC operations by prescribing zero tax deduction at source on certain payments made to IFSC units eligible for deduction under Section 80LA [8]. This notification eliminates the cash flow burden associated with tax withholding and subsequent refund processes, effective from July 1, 2025.

Beyond income tax benefits, GIFT City entities enjoy exemption from Securities Transaction Tax, Commodity Transaction Tax, and stamp duty on transactions conducted on IFSC exchanges. The GST framework applicable to IFSC units treats them as operating in a non-taxable territory for certain transactions, creating additional cost advantages.

Regulatory Oversight and Fit and Proper Criteria

The GRCTC framework incorporates stringent fit and proper criteria ensuring that entities and individuals involved in treasury center operations meet high standards of integrity and competence. These criteria apply to Relevant Persons, defined as the applicant entity, its Key Managerial Personnel, and persons exercising control over it.

The fit and proper assessment encompasses multiple dimensions. Regulatory history is scrutinized, with applicants required to disclose whether any relevant person or entities associated with them have been refused registration, authorization, or license by IFSCA or any other regulatory authority, or had such registration suspended. Default history must be disclosed, including whether relevant persons or associated entities are in default or have defaulted in respect of credit facilities obtained from any entity or bank.

Disqualifications under corporate law are examined, with disclosure required if any relevant person has been disqualified from acting as promoter, director, or key managerial personnel under any law in any jurisdiction where the applicant or its group entities operate. Substantial interests in other companies must be disclosed to identify potential conflicts of interest or concentration of control.

Investigative and disciplinary matters receive careful attention. Applicants must disclose whether they or relevant persons are undergoing or involved in any investigation, disciplinary action, legal or regulatory violations, or criminal cases by law enforcement or regulatory agencies. Orders passed by bankruptcy or resolution authorities against companies or entities with which relevant persons are associated must be disclosed.

Criminal convictions for offences involving moral turpitude, economic offences, or offences against securities laws result in disqualification. Pending recovery proceedings initiated by financial regulatory authorities, winding-up orders for malfeasance, orders restraining or prohibiting dealing in financial products or services, and other regulatory orders within the past five years all factor into the fit and proper assessment.

Insolvency, unsound mind declarations, classification as willful defaulter, designation as fugitive economic offender, and financial unsoundness all constitute grounds for potential disqualification. Applicants must undertake to notify IFSCA immediately of any material change in information provided, including proceedings, charges, or investigations initiated against the applicant or relevant persons.

Fee Structure and Financial Implications

The GRCTC framework establishes a straightforward fee structure designed to cover regulatory costs while remaining competitive with other international financial centers. The fee structure comprises three components: an application fee, registration fee, and recurring fee.

The application fee stands at USD 1,000 and is non-refundable, payable at the time of submission of the registration application. This fee covers the administrative costs of processing applications and conducting preliminary assessments. The registration fee of USD 12,500 is a one-time charge payable upon grant of Certificate of Registration, covering the regulatory costs associated with bringing a new entity into the IFSC ecosystem [5].

The recurring fee is set at USD 25,000 per annum, payable for ongoing supervision and regulatory oversight. For existing Finance Companies or Finance Units already undertaking GRCTC activities, the revised fee structure became applicable from the beginning of financial year 2025-26, providing a clear transition timeline.

An important exemption applies to GRCTCs also engaging in factoring activities. Where a Finance Company or Finance Unit granted registration for GRCTC activities subsequently applies for registration under the IFSCA (Registration of Factors and Registration of Assignment of Receivables) Regulations, 2024, it is not required to pay separate registration and recurring fees for factoring activities. This exemption recognizes that factoring represents a permissible activity within the GRCTC framework and avoids duplicative fee obligations.

The fee structure must be viewed in context of the minimum owned fund requirement of USD 0.2 million and the potential tax benefits available under Section 80LA. For entities with significant treasury operations spanning multiple jurisdictions and involving substantial transaction volumes, these fees represent a modest regulatory cost relative to the operational efficiencies and tax savings achievable through the GIFT City platform.

Comparative Advantages and Global Positioning

GIFT City’s GRCTC framework positions India to compete with established treasury center hubs including Singapore, Hong Kong, Dubai, and European financial centers. Several factors contribute to GIFT City’s competitive positioning. Cost effectiveness stands out prominently, with operational and setup costs significantly lower than in traditional financial hubs while maintaining comparable regulatory standards and infrastructure quality.

The skilled workforce available in India, particularly in financial services and technology domains, provides GRCTC operations access to talent at competitive compensation levels. India’s geographic location offers timezone advantages, enabling operations to cover both Asian and European trading hours effectively. The strategic position provides access to rapidly growing Asian, Middle Eastern, and African markets.

Regulatory alignment with international standards, combined with a unified regulatory authority in IFSCA, creates a business-friendly environment with streamlined approvals and reduced compliance complexity. The tax incentives under Section 80LA and related provisions provide substantial cost advantages, particularly during the initial ten-year period of complete income tax exemption.

Infrastructure development in GIFT City has accelerated, with world-class office facilities, technology infrastructure, and supporting ecosystem participants including banks, insurance companies, fund managers, and market intermediaries establishing presence. The growing ecosystem creates network effects, as the presence of multiple financial institutions enhances the value proposition for new entrants.

However, GIFT City faces certain challenges in competing with established hubs. The ecosystem is still maturing, with liquidity and market depth in certain instruments not yet matching that of established centers. Perception challenges persist, as some international corporations remain more familiar and comfortable with traditional hubs. Regulatory interpretations continue to evolve as IFSCA gains experience, creating some degree of uncertainty compared to well-established regulatory frameworks in mature jurisdictions.

Recent Developments and Future Outlook

The GRCTC framework continues to evolve based on market feedback and emerging best practices. The June 9, 2025 amendment to the GRCTC Framework introduced under Circular No. F. No. IFSCA/24/2024-Banking-FC/02 added a new provision under Clause 3(2)(ii) allowing the Chairperson of IFSCA to grant temporary relaxation from specific conditions in the GRCTC Framework [9]. This provision enhances regulatory flexibility to address genuine hardship cases while maintaining overall framework integrity.

Industry stakeholders have advocated for further clarifications on certain aspects of the framework. Commodity hedging guidelines, particularly for exchange-traded contracts, remain an area where comprehensive guidance would be beneficial. Transfer pricing provisions applicable to inter-unit transactions between GIFT City units and their parents or group entities require further clarification, particularly regarding the applicability of Section 92BA of the Income Tax Act to specified domestic transactions.

The regulatory convergence challenge persists, as GRCTC operations intersect with multiple regulatory domains including RBI regulations governing foreign exchange transactions, SEBI regulations applicable to capital markets activities, corporate law under the Companies Act, 2013, and tax regulations under the Income Tax Act. Ensuring seamless coordination among these regulatory frameworks remains an ongoing priority.

Looking forward, GIFT City’s GRCTC framework holds significant promise for establishing India as a preferred destination for global treasury operations. The government’s commitment to developing the IFSC ecosystem, combined with IFSCA’s responsive regulatory approach, creates a favorable environment for growth. The increasing number of multinational corporations evaluating GIFT City for treasury operations suggests growing market acceptance.

Conclusion

The Global and Regional Corporate Treasury Centre (GRCTC) framework represents a critical component of India’s strategy to position GIFT City as a competitive international financial services center. Through careful regulatory design, attractive tax incentives, and operational flexibility, the framework provides multinational corporations with a compelling value proposition for centralizing treasury functions in India.

The legal foundations established through the IFSCA Act, 2019, the SEZ Act, 2005, and supporting regulations create a robust framework balancing regulatory oversight with ease of doing business. The revised GRCTC framework effective from April 4, 2025, incorporates lessons learned from initial implementation and stakeholder feedback, introducing enhancements around substance requirements, operational flexibility, and regulatory clarity.

Tax benefits under Section 80LA of the Income Tax Act, 1961, provide substantial financial incentives, effectively creating a decade-long tax holiday for qualifying income. Combined with exemptions from securities transaction tax, commodity transaction tax, and beneficial GST treatment, the tax framework significantly enhances the economics of operating treasury centers from GIFT City.

Governance and compliance requirements ensure that GRCTCs maintain high operational standards, with board-approved policies for corporate governance, risk management, and permissible activities. Fit and proper criteria applicable to entities and individuals ensure integrity within the ecosystem.

As GIFT City’s ecosystem continues to mature, with growing participation from global financial institutions, fund managers, and market intermediaries, the network effects will strengthen the value proposition. While challenges remain in competing with established treasury center hubs, the combination of cost advantages, regulatory support, tax incentives, and access to skilled talent positions GIFT City favorably for future growth.

The GRCTC framework demonstrates how thoughtful regulatory design, informed by international best practices and responsive to market needs, can create competitive advantages for emerging financial centers. As India continues its economic ascent and integration with global financial markets, GIFT City’s role as a hub for centralized treasury functions is poised to expand, contributing to the broader objective of establishing India as a significant player in international finance.

References

[1] International Financial Services Centres Authority Act, 2019 (Act No. 50 of 2019). Available at: https://ifsca.gov.in/Legal/Index/sKCVtbX6J9o= 

[2] ATB Legal. (2025). GIFT City and IFSC in India: A Detailed Legal Perspective. Available at: https://atblegal.com/blog/business-legal-structures-in-india/ifsc-in-india/ 

[3] IFSCA Circular dated June 25, 2021. Framework for undertaking Global/Regional Corporate Treasury Centres Activities by Finance Company/Finance Unit in IFSC. Available at: https://ifsca.gov.in/Document/Legal/circular_global-regional-corporate-treasury-centre_june-25-202125062021034458.pdf 

[4] IFSCA Consultation Paper dated September 12, 2024. Draft Public Consultation on GRCTC Framework Revision. Available at: https://www.ifsca.gov.in/Document/ReportandPublication/draft-public-consultation-on-grctc-framework-revision-12-09-202412092024065814.pdf 

[5] IFSCA Circular F. No. IFSCA/24/2024-Banking-FC/01 dated April 4, 2025. Framework for Finance Company/Finance Unit undertaking the activity of Global/Regional Corporate Treasury Centres. Available at: https://ifsca.gov.in/Document/Legal/01-framework-for-grctc_updated04042025061059.pdf 

[6] Section 80LA, Income Tax Act, 1961. IndiaFilings. (2025). Section 80LA Deduction – Income Tax Act. Available at: https://www.indiafilings.com/learn/section-80la-deduction/ 

[7] Finance Act, 2023. Explanatory Notes to the Provisions of the Finance Act, 2023. Available at: https://www.voiceofca.in/siteadmin/document/CBDTreleasesexplanatorynotespertainingtoprovisionsoftheFinanceAct2023.pdf 

[8] GIFT CFO. (2025). TDS Exemption for GIFT City Units from July 1, 2025. Available at: https://www.giftcfo.com/post/tds-exemption-for-gift-city-units-from-july-1-2025-big-boost-for-ifsc-businesses 

[9] Sarthak Law. (2025). GIFT City – Amendment to the ‘Framework for Finance Company/Finance Unit undertaking the activity of Global/Regional Corporate Treasury Centres’. Available at: https://sarthaklaw.com/gift-city-amendment-to-the-framework-for-finance-company-finance-unit-undertaking-the-activity-of-global-regional-corporate-treasury-centres/