Global & Cross-Border Insurance - June 28, 2026 - 5 min read
OECD Pillar Two and the Captive Question: Will the 15% Global Minimum Tax Erode the Case for Indian Corporates' Offshore Captives?
The global minimum tax changes the arithmetic of captives domiciled in low-tax centres for in-scope Indian groups. CFOs and brokers need the top-up-tax mechanics, the OECD's insurance-specific guidance and safe harbours, and a clear-eyed view that the captive case now rests on risk, capacity and data rather than tax arbitrage. This post sets out the mechanics and positions GIFT City onshore captives as a substance-rich alternative.
By Sarvada Editorial Team