Corporate Treasury and Commodity Trading Centre (CTCTC) structure

How India is enhancing GIFT City’s value as a global corporate treasury hub

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Gujarat International Finance Tec-City (GIFT City) can become a top global financial hub for organizations looking to set up Global/Regional Corporate Treasury Centres (GRCTCs).


In brief

  • India defines regulations to make GIFT City a key hub for GRCTCs, addressing policy gaps and operational hurdles for global treasury setups.
  • IFSCA issues frameworks and updates to clarify GRCTC activities and ease the process of setting up treasury operations in GIFT City.
  • 2024 consultation paper1 and April 2025 circularaddress ambiguities and reflect stakeholder input to boost clarity and investor confidence.


Amid growing global volatility, multinational corporations are re-evaluating how they manage liquidity, financial risk and commodity trading. Centralized Global/Regional Corporate Treasury Centres (GRCTCs) are emerging as a strategic solution to these challenges. Acting as internal hubs for financing and commodity-related activities, GRCTCs enable companies to streamline operations, enhance transparency, and optimize financial and trading decisions across jurisdictions.

Taking a closer look at India’s regulatory efforts to position GIFT City as a destination for GRCTCs, we examine the International Financial Services Centres Authority’s (IFSCA) frameworks and recent revisions aimed at clarifying permissible activities and enhancing the ease of establishing GRCTCs. 

Understanding Corporate Treasury and Commodity Trading Centres: Purpose, functions and structure 

A GRCTC operates as an internal banking and commodity trading hub for multinational companies with operations across various geographies. Its primary goal is to centralize fund management, facilitate commodity trades, manage trading costs, and enhance financial resource utilization across the group. 

It serves as a centralized hub for financial, trading, and hedging activities, enabling tighter control, better risk mitigation, and improved strategic alignment across the organization. By standardizing processes and policies, it helps ensure transparency, consistency and cost efficiency. Centralizing these functions also enhances the group’s ability to negotiate favorable terms with banks and financial counterparties. 

Why GRCTCs matter: Business drivers and benefits

CFOs, treasurers, and trading heads are experiencing stress due to rising geopolitical uncertainties. From navigating volatility in foreign exchange and commodity prices to maintaining robust liquidity and cash flow, many are now focusing on aligning and strengthening their treasury and commodity trading strategies. 

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The key benefits of establishing a successful GRCTC are:

  • Group-wide transaction netting and cash visibility
  • Availability of tax incentives provided by local governments
  • Proximity and access to financial and trading counterparts, and market participants
  • Ease of doing business and availability of various market participants
  • Efficient commodity trading and hedging
  • Adoption of Treasury and Commodity Trading and Risk Management (CTRM) technology
  • Operational benefits, such as reduced costs and streamlined processes

Designing the GRCTC: Key structural considerations 

Designing the GRCTC: Key structural considerations

Designing the GRCTC: Key structural considerations

Spotlight on India: Gujarat International Finance Tec-City (GIFT City) and International Financial Services Centre (IFSC)

GIFT City was established as a smart city with a clear goal: to offer a wide range of financial services—like banking, insurance, capital markets, and asset management—through an International Financial Services Centre (IFSC). These services are designed for entities seeking to transact in foreign currencies rather than Indian Rupees.

In support of the GRCTC initiative, the IFSC unveiled a comprehensive framework titled, "Global/Regional Corporate Treasury Centre Activities by Finance Company/Finance Unit,"3  in June 2021, listing the permissible treasury activities and services for FX risk management, cash management, fundraising, intra-group financing, and trading in commodity derivatives. 

Following the release of the GRCTC framework by IFSCA, the setup of regional treasury centers in GIFT City has been a key point of interest for many companies. To facilitate this, the IFSCA issued a consultation paper proposing revisions to the current framework. It sought feedback, insights, comments, and suggestions from the public, market participants, and stakeholders regarding the existing guidelines and framework. 

To drive greater business participation, further clarification and simplification of permissible treasury activities in GIFT City are necessary. These updates would help organizations evaluate how to set up full-fledged trading entities and treasury operations. Key drivers include:

1. Procurement, export and trading activities:

The revised guidelines (dated 5 April 2025) offer clarity on the GRCTC’s role as a re-invoicing center. GRCTCs can now facilitate the financing of goods bought and sold on behalf of service recipients, supporting operations under a Bill-to-Ship-to model—subject to adherence with shipping laws and regulations.

2. Guidelines on commodity trading:

A lack of clear regulations for Over-The-Counter (OTC) and physical commodity trading has restricted institutional investor participation. A formal regulatory framework will help integrate India more deeply into global trade.

3. Cash pooling activities:

While cash pooling is permitted by the IFSCA, cash pooling guidelines can be enhanced to explicitly cover physical, notional, and cross-currency pooling structures.

4. Currency, commodity and interest rate hedging:

The revised guidelines (dated 5 April 2025) clarify that OTC derivatives can be transacted with both internal and external counterparties. However, comprehensive regulations for hedging commodities—both OTC and exchange-traded—are still required.

5. Freight hedging:

Just as Foreign Exchange (FX) and commodity hedging, businesses have emphasized the importance of freight hedging to become a permitted activity, along with uniform guidelines. Currently, many global firms conduct this from hubs like Dubai and Singapore.

6. Trade credit and freight insurance counterparts:

Establishment of trade credit and freight insurance companies in GIFT City is immensely important for corporations involved in factoring and supply chain financing activities. The presence of these counterparts enhances GIFT City’s appeal as a comprehensive financial ecosystem. Due to tax incentives, trade credit and freight insurers may offer competitive premiums, making it more affordable for businesses to secure insurance for factoring deals.

7. Trade finance solutions:

GIFT City should offer a full suite of trade finance solutions—factoring, forfaiting, receivables finance, supply chain finance and invoice discounting—to strengthen its appeal.

GIFT City has the potential to rank among the world’s leading financial hubs for organizations looking to establish GRCTCs. With supportive regulations, growing infrastructure, and increasing industry interest, it offers multinational corporations an attractive new base for global treasury and commodity trading operations-signaling a promising future for India on the global financial stage.


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    Summary

    Given the diverse array of regulatory bodies such the RBI, SEBI, FEMA, the Companies Act, Transfer Pricing regulations and Income-tax laws overseeing the treasury activities within the Indian jurisdiction, it is essential to establish a simple roadmap to converge and facilitate these regulations and transactions to be conducted within the GIFT City jurisdiction.

    This implementation will ensure that treasury activities can be performed smoothly and seamlessly. Aligning with existing regulations will not only enhance compliance but also promote transparency and efficiency, eventually supporting growth and stability in GIFT City.

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