Foreign Wholly Owned Subsidiary in India
100% foreign ownership. Full operational capability. The cleanest way for a foreign company to operate in India — with proper FEMA compliance and transfer pricing documentation from day one.
Set up your 100% WOS in India
FDI route advisory, incorporation and RBI reporting — handled as one engagement.
Talk to a CS →From FDI route to a fully operational Indian WOS
FDI Sector Advisory
100% FDI eligibility confirmed for your sector — automatic vs approval route.
SPICe+ Incorporation
WOS incorporated with foreign company as the sole shareholder.
FC-GPR & RBI Filing
Foreign investment reported to AD bank and RBI within 30 days of allotment.
Transfer Pricing Setup
Intercompany transaction policy and TP documentation framework established.
Annual FLA Return
Annual Foreign Liabilities and Assets return filed with RBI.
DTAA Analysis
Applicable tax treaty identified to optimise dividend withholding tax on repatriation.
What a 100% foreign-owned WOS must comply with in India
100% Foreign Shareholding
No Indian shareholder; foreign company holds all shares directly.
Resident Indian Director
At least one director must be an Indian resident — mandatory for incorporation.
FC-GPR Within 30 Days
RBI reporting on foreign investment — automatic penalty for delay.
Transfer Pricing Compliance
All transactions with the foreign parent are international transactions subject to TP rules.
Annual FLA Return
RBI filing by July 15 each year.
Corporate Tax at 22%
WOS pays corporate income tax at 22% base rate under Section 115BAA if opted.
Transfer pricing applies to every transaction between a WOS and its foreign parent — management fees, royalties, loans, services and goods. Arm's length documentation must be in place before transactions begin, not after a tax audit notice arrives.
Common issues in WOS setup and operation
Simple steps, no surprises
FDI & TP advisory
Sector FDI eligibility confirmed; TP framework and intercompany agreement advised.
Incorporation filing
SPICe+ filed with foreign company as sole shareholder; resident director appointed.
FC-GPR & RBI reporting
Investment reported within 30 days; FIRC and KYC documents compiled.
Operational compliance
FLA return, TP documentation, annual filings and repatriation advisory ongoing.
Other services you may need
Frequently asked questions
A WOS is an Indian company in which 100% of the shares are held by a single foreign company. No Indian shareholder exists.
Most sectors allow 100% FDI under the automatic route. Some sectors require government approval. We confirm this before filing.
Yes. A WOS is a separate Indian legal entity — it can hire, sign contracts, own assets, open bank accounts and raise invoices in India.
No statutory minimum. Typically a nominal initial capital (e.g. Rs 1 lakh) is used at incorporation with further capitalisation as needed.
After paying Indian corporate tax, the WOS can declare a dividend. Repatriation requires withholding tax compliance and may benefit from a DTAA reduced rate.
Yes, through External Commercial Borrowing (ECB) subject to RBI's ECB framework.
Indian corporate filings (AOC-4, MGT-7, IT return), FEMA filings (FC-GPR, FLA return) and transfer pricing compliance.
Set up your Wholly Owned Subsidiary in India — compliantly
Share your parent company details, sector and intended operations. We will handle FDI route, SPICe+ and RBI reporting.