A global capability centre that invoices its foreign parent or group companies for services is a service exporter, so those invoices go on the monthly Export Declaration Form like anyone else's. Intra-group billing gets no exemption: every cost-plus invoice dated in a month goes on one EDF, due within 30 days from the end of that month, filed with the AD bank, STPI (for software) or the SEZ Development Commissioner if the centre is an SEZ unit. For GCCs, the real work lies in quarterly true-ups, transfer-pricing adjustments and multi-entity billing.
Key takeaways
- Invoices to a parent or affiliate abroad are exports for FEMA purposes and must be declared.
- SEZ-based GCCs file with the SEZ Development Commissioner; others file with the AD bank, or STPI for software.
- Cost-plus invoices, quarterly true-ups and year-end adjustments each go on the EDF in the month they are raised.
- Realisation within 9 months of each invoice date applies to group receivables too.
- GST export status needs care: Section 2(6) excludes supplies between mere establishments of a distinct person.
Why GCCs cannot treat group billing as internal
Inside a multinational, a GCC's invoice to its parent can feel like a ledger entry. Under FEMA it is a cross-border service export with foreign exchange to realise. Your AD bank enters each EDF into EDPMS and expects every invoice to be paid within the realisation window, whether the client is a stranger or your own headquarters.
That has a practical upside. Group payments are predictable, so a GCC that bills cleanly should rarely have open entries. Problems tend to come from netting, delayed true-ups and invoices raised by one group entity but paid by another.
Filing route: depends on where the centre sits
| GCC setup | EDF goes to | Notes |
|---|---|---|
| SEZ unit | SEZ Development Commissioner | Category of exporter at field 1.5: SEZ |
| Non-SEZ, mainly software or engineering | AD bank or STPI | STPI certification no longer mandatory |
| Non-SEZ, business services (finance, HR, analytics) | AD bank | Category usually "Others" |
| Multiple Indian entities | Each entity files its own EDF | One EDF per entity per month |
| 100% EOU | AD bank | Category of exporter: 100% EOU |
If your GCC has both SEZ and non-SEZ units, each files through its own route. Our guide on SEZ units and the EDF covers the Development Commissioner process.
Cost-plus billing and true-ups
Most GCCs bill the parent on a cost-plus basis: actual costs plus an agreed mark-up, often invoiced monthly on budgeted costs and trued up quarterly or annually.
- Monthly provisional invoice: declare it on that month's EDF.
- Quarterly true-up invoice (upward): a new invoice, declared in the month it is raised.
- True-up credit note (downward): link it to the original invoices it reduces and tell your AD bank, since realisation on those invoices will be lower.
- Year-end transfer-pricing adjustment: treat it the same way, as an invoice or credit note in the month raised. Ask your CA how it interacts with tax filings.
Keep a schedule mapping every true-up to the invoices it adjusts. When the bank asks why March's invoice was paid 4% short, you want to answer in one email.
Codes, hedged
GCCs do everything from software engineering to finance operations, so codes vary by centre and sometimes by team.
- Engineering and IT: SAC 998314 or 998313; purpose codes P0802 or P0807.
- Finance and accounting: SAC 998222 (accounting and bookkeeping); purpose code P1005 (accounting, auditing and tax consulting).
- Research and development: purpose code P1008 (R&D services) may fit.
- Analytics and business support: P1006 (business and management consultancy) is sometimes used.
These are starting points, not answers. Where one invoice covers several functions, your CA should advise on classification, and your bank decides the purpose code it applies. See our SAC code finder to shortlist options.
Worked example: a quarter at a non-SEZ GCC
Aldergate Shared Services India Pvt Ltd in Hyderabad provides engineering and finance support to its US parent and a German affiliate, on cost plus 15%.
October 2026 invoices:
| Row | Recipient | Invoice | Date | Description | Amount |
|---|---|---|---|---|---|
| 1 | US parent | ASS/26/10-01 | 2 Oct | Engineering services, October, provisional | USD 410,000 |
| 2 | US parent | ASS/26/10-02 | 2 Oct | Finance operations, October, provisional | USD 96,000 |
| 3 | German affiliate | ASS/26/10-03 | 2 Oct | Engineering services, October, provisional | EUR 72,000 |
| 4 | US parent | ASS/26/10-04 | 15 Oct | Q2 true-up (July to September) | USD 18,700 |
All four rows went on the October EDF, due 30 November 2026. Each is above ₹10 lakh, so closure needs FIRAs and matching instructions.
In January 2027, the Q3 true-up showed the German affiliate had been overbilled by EUR 3,100. Aldergate issued a credit note against the October to December invoices for that affiliate, apportioned EUR 1,000, EUR 1,050 and EUR 1,050, and wrote to its AD bank explaining the reduced realisation on each.
Realisation, netting and who pays
Three issues recur at GCCs:
- Netting. Group treasuries sometimes want to net amounts the GCC owes the parent against amounts the parent owes the GCC. Set-off of export receivables is a regulated matter; do not net without your AD bank's agreement.
- Payment from a different group entity. If a group treasury company pays on behalf of the contracting entity, use the third-party fields (1.15 and 1.16) and keep the authorisation on file.
- Late true-ups. Raise them promptly. A true-up paid eleven months after the invoice it relates to creates its own 9-month window, but delays muddy the audit trail.
GST: the distinct-person caution
Export of services is zero-rated when the five Section 2(6) IGST conditions are met. One condition is that the supplier and recipient are not merely establishments of a distinct person. A GCC that is a separate Indian company billing its foreign parent is generally a different legal person, but structures vary, especially for branch-type setups. Your CA should confirm export status. The EDF itself does not change GST or income-tax obligations.
This is general information, not legal or tax advice.
Frequently asked questions
Do GCCs need to file the EDF for invoices to their own parent company?
Yes. Invoices from an Indian GCC to a foreign parent or affiliate are service exports under FEMA. They go on the monthly EDF and must be realised within the applicable period.
Where does an SEZ-based GCC file its EDF?
With the SEZ Development Commissioner, not the AD bank. Mark the category of exporter as SEZ at field 1.5.
How are quarterly true-up invoices declared?
As new invoices in the month they are raised. Downward true-ups are credit notes linked to the original invoices; tell your AD bank so it can match the reduced realisation.
Can the parent net what it owes us against what we owe it?
Set-off of export receivables is regulated. Do not net amounts without speaking to your AD bank first and following the applicable rules.
Bottom line
For a GCC, the EDF is mostly a mirror of the intercompany billing calendar, with care needed at true-ups and netting. Keep every adjustment linked to its source invoice and talk to your bank before netting anything. Build each month's form quickly with our free EDF form generator.
This guide is general information for Indian businesses, not legal or tax advice. Rules and bank processes change — confirm specifics with your AD bank or chartered accountant.