VJM Global advises managers and corporate groups in the United States, the United Kingdom, Hong Kong, Singapore, and Japan on Cayman fund and holdco structures with Indian deployment, and Indian sponsors raising offshore capital through Cayman vehicles. We own the India advisory leg and partner with leading Cayman law firms.
The Cayman Islands is the world's leading offshore fund domicile, hosting over 30,000 regulated investment funds and around 8.2 trillion US dollars in assets at end-2024. Tax neutrality, English common law, world-class CIMA regulation, and same-day company incorporation make Cayman the default choice for hedge funds, private equity, captive insurers, and cross-border holding structures. For Indian sponsors and inbound managers, Cayman pairs with FEMA, SEBI AIF, and Section 9A frameworks.
0% direct tax on income, capital gains, dividends, and inheritance. Tax exemption certificates run 20 years for exempted companies and 50 years for limited partnerships, LLCs, and trusts. Pillar Two top-up applies only above EUR 750m.
Final court of appeal sits in London. The Grand Court has a specialist Financial Services Division. Common law precedent on trusts, fund governance, and complex commercial disputes is well developed and predictable for international counterparties.
Removed from the FATF increased monitoring list in October 2023 and from the EU AML list in February 2024. CIMA enforces the Anti-Money Laundering Regulations 2020, FATCA, CRS, and economic substance rules, sustaining institutional investor confidence.
Companies, LLCs, and exempted limited partnerships can be incorporated on the same day on an express basis. There are no exchange controls, no minimum capital requirements, and no restrictions on the movement of funds in or out of the jurisdiction.
Cayman offers seven principal entity types for fund formation, holding companies, captive insurance, and private wealth structures. Selection depends on capital structure, investor profile, regulatory regime, and exit strategy. The exempted company and exempted limited partnership cover most fund and holdco use cases. The LLC, SPC, foundation company, and STAR trust serve specific structuring needs.
| Feature | Exempted Company | Exempted LP | LLC | SPC |
|---|---|---|---|---|
| Legal status | Body corporate | Partnership without legal personality | Body corporate, Delaware-style | Single legal person, segregated cells |
| Foreign ownership | 100% permitted | 100% permitted | 100% permitted | 100% permitted |
| Capital requirement | None statutory | None statutory | None statutory | None statutory |
| Setup timeline | Same-day on express | Same-day on express | Same-day on express | Same-day on express |
| Taxation | 0% direct tax; 20-yr exemption certificate | 0% direct tax; 50-yr exemption certificate | 0% direct tax; 50-yr exemption certificate | 0% direct tax; 20-yr exemption certificate |
| Best for | Hedge fund masters, holdcos, captives | Private equity, venture capital, real estate funds | Joint ventures, holdco flexibility, hybrid structures | Multi-class funds, captive cell programmes, ILS |
We model the Cayman entity selection alongside the Indian leg of the structure. For inbound fund managers, we run the FPI/AIF route analysis under SEBI AIF Regulations 2012 and the Section 9A safe harbour test under the IT Act 1961. For Indian sponsors raising offshore, we stress-test corpus thresholds, manager remuneration, and POEM exposure before incorporation.
VJM Global delivers two streams of work for Cayman-linked engagements. The inbound stream supports US, UK, Hong Kong, Singapore, and Japanese fund managers and corporate groups using Cayman vehicles to deploy capital into India: FPI registration, AIF setup, transfer pricing, GAAR opinions, and ongoing tax compliance. The outbound stream supports Indian sponsors raising offshore capital via Cayman, including Section 9A safe harbour structuring, FEMA ODI filings, and dual-fund design.
Deep experience across the industries that drive Cayman activity. We work with hedge fund and private equity managers, captive insurance and reinsurance groups, structured finance and ILS issuers, holding companies, family offices, and digital asset funds. Each industry brings different regulatory intersections between Cayman, India, and the home jurisdiction.
We work with international fund managers, multinational corporate groups, and Indian sponsors whose Cayman structures intersect with India. Whether the engagement starts at fund formation, FPI onboarding, group restructuring, or pre-IPO planning, we anchor the India leg and coordinate with Cayman counsel and administrators on the offshore side.
We anchor the India advisory leg for hedge fund and private equity managers in the United States, the United Kingdom, Hong Kong, Singapore, and Japan that use Cayman master-feeder or exempted limited partnership structures to deploy capital into India.
Engagements typically cover FPI Category I, II, or III registration, AIF Cat-II setup, custodian onboarding, transfer pricing on management fees, GAAR opinions, and ongoing tax compliance for portfolio investments.
We work with Mumbai, Bengaluru, Delhi-NCR, Chennai, and Hyderabad-headquartered private equity, venture capital, and family-office sponsors launching Cayman exempted limited partnerships to raise capital from US, UK, GCC, and Asian institutional investors.
The mandate covers Section 9A safe harbour structuring, Indian manager LLP setup, FEMA ODI declarations, dual-fund design with an Indian AIF Cat-II mirror, and GIFT City IFSC migration analysis.
We support multinational corporate groups headquartered in the United States, the United Kingdom, Hong Kong, Singapore, and Japan that hold their Indian operating subsidiaries through a Cayman exempted company, often via Mauritius or Singapore intermediate entities for treaty access.
Work spans GAAR substance memos, transfer pricing master file and CbCR, Pillar Two top-up assessments, FEMA NDI compliance, and pre-IPO restructuring under Section 47 of the Income Tax Act 1961.
We advise Indian corporate groups and multinational parents that use Cayman captive and reinsurance structures regulated by CIMA. The audience includes manufacturing, healthcare, technology, and financial services groups managing enterprise risk through captive cells.
Indian-side support covers FEMA ODI for the captive equity, transfer pricing on intra-group reinsurance, GST on premiums, IRDAI coordination, and ongoing audit and tax compliance for Indian shareholders.
Our team handles the Indian leg of every Cayman engagement: FPI registration, AIF Cat-II setup, Section 9A safe harbour analysis, FEMA ODI declarations, transfer pricing studies, GAAR opinions, and ongoing audit and tax compliance. You retain your Cayman law firm and administrator. We coordinate the India workstream so the structure stays operational quarter after quarter.
FCA Kapil Mittal leads on international tax, transfer pricing, and FEMA advisory. FCA Sachin Jindal leads on multi-country incorporation and structure design. The team has built FPI and AIF compliance frameworks for funds based in the United States, the United Kingdom, Hong Kong, Singapore, and Japan, and Section 9A safe harbour roadmaps for Indian sponsors raising offshore.
We work routinely with Maples, Walkers, Mourant, Appleby, Harneys, and Ogier on the Cayman side, alongside major fund administrators and CIMA-registered service providers. Indian clients new to Cayman receive a coordinated introduction. Existing managers retain their Cayman counsel and bring us in for the India workstream when their structure touches India.
Our pricing is aligned to mid-market funds and mid-market corporate groups. Engagements are scoped on a fixed-fee basis for setup work and a retainer model for ongoing compliance, with clear deliverables tied to the Indian fiscal year. We share scope and fee structures during the initial scoping call before any work begins so there are no surprises later.
Managers in the United States, the United Kingdom, Hong Kong, Singapore, and Japan choose VJM because we own the India side end-to-end. We draft the Section 9A position, file the FEMA ODI, register the FPI, run the transfer pricing study, and handle ongoing audit and tax compliance. We coordinate directly with Maples, Walkers, Mourant, Appleby, Harneys, and Ogier on the Cayman side.
Anonymised engagements showing how we anchor the India advisory leg of Cayman fund and holding structures. Each story highlights the specific Indian regulatory framework applied and the outcome delivered for the client.
Profile: US long/short hedge fund, USD 1.2 billion AUM, Cayman master-feeder, expanding India equity sleeve.
Challenge: FPI Category-II registration, custodian onboarding, Section 112A/111A capital gains compliance, and transfer pricing on master-feeder management fees.
VJM Role: Filed FPI registration via Mumbai custodian, prepared Section 92F study, built quarterly calendar for capital gains, FATCA, CRS.
Outcome: FPI live within the quarter; first India deployment completed; ongoing compliance under retainer.
Profile: Mumbai PE sponsor, deep-tech, launched a USD 200 million Cayman exempted limited partnership and a SEBI Cat-II AIF mirror.
Challenge: Section 9A IT Act 1961 safe harbour — corpus, beneficial owner concentration, manager remuneration, POEM — plus FEMA ODI Rules 2022 approval.
VJM Role: Structured the dual-fund vehicle, set up Indian manager LLP, prepared Section 9A framework, filed FEMA ODI declaration.
Outcome: Both funds live; Section 9A monitored quarterly; first close with US, Singapore, Indian LPs.
Profile: UK-listed tech group with Cayman holdco and Indian operating subsidiary restructured ahead of an IPO.
Challenge: Pillar Two top-up, GAAR scrutiny on Cayman holdco substance, intra-group transfer pricing, and Section 47 IT Act tax-neutral restructuring.
VJM Role: Modelled Pillar Two ETR, prepared GAAR substance memo, refreshed master file and CbCR, structured merger documentation.
Outcome: Restructuring completed without GAAR challenge; Pillar Two impact mitigated; India entity ready for IPO filing.
VJM Global anchors the India advisory leg of Cayman fund and holding structures. We support international fund managers using Cayman vehicles to deploy capital into India with FPI registration, AIF Cat-II setup, Section 9A safe harbour structuring, transfer pricing, GAAR opinions, and ongoing audit and tax compliance. We also support Indian sponsors raising offshore capital through Cayman with FEMA ODI filings, dual-fund design, and Section 9A qualification monitoring. We coordinate with Cayman law firms and administrators on the offshore side.
We own the India side of cross-border Cayman engagements. Our team is led by FCA Kapil Mittal and FCA Sachin Jindal, qualified chartered accountants with 20+ years of cross-border experience. We have built FPI and AIF compliance frameworks for funds based in the United States, the United Kingdom, Hong Kong, Singapore, and Japan. We work routinely with Maples, Walkers, Mourant, Appleby, Harneys, and Ogier on the Cayman side. Our pricing is aligned to mid-market funds and corporate groups.
We do not register Cayman entities ourselves. Cayman counsel handles entity formation. We provide everything that connects the Cayman entity to India: FPI registration with SEBI, AIF Cat-II setup, custodian and broker onboarding, Section 9A safe harbour analysis and monitoring, FEMA ODI declarations through an authorised dealer bank, transfer pricing studies under Section 92F, GAAR opinions, FATCA and CRS reporting, ongoing India direct tax compliance, withholding tax, and Indian audit for portfolio entities. The engagement runs across the India fiscal year.
Cayman-linked structures touch SEBI for FPI and AIF, RBI for FEMA, the Income Tax Department for tax and transfer pricing, the Ministry of Corporate Affairs for any Indian operating company or manager LLP, and IRDAI when captives are involved. We map the obligations across these regulators into a single compliance calendar tied to the Indian fiscal year. The calendar shows filing deadlines, owner per filing, source documents required, and dependencies. We coordinate directly with custodians, authorised dealer banks, and Cayman fund administrators to keep the structure operational.
Our delivery uses Zoho Books for accounting, Zoho Projects for engagement tracking, Zoho CRM for client onboarding, and Zoho Analytics for compliance dashboards. We are ISO 27001 certified, which mandates information security controls across systems, devices, and team workflows. For fund-side reporting, we coordinate with the Cayman fund administrator's portal, share data via secure file transfer, and provide India-side reporting in formats that match your existing investor and CIMA reporting cycle.
Cayman-domiciled groups often need Indian-based portfolio analysts, deal teams, or operations staff before an Indian entity is registered. We support the EOR phase by structuring the engagement model, advising on Section 9 IT Act PE risk, GST registration when service rendering crosses thresholds, TDS obligations, and transition planning to a permanent Indian entity. When the group is ready to incorporate, we handle the LLP or private limited setup under Companies Act 2013 and the migration of staff and contracts.
VJM Global is ISO 27001 certified, which mandates documented controls across access management, encryption, secure storage, and incident response. Client data sits in jurisdictionally-appropriate cloud environments with role-based access. We use multi-factor authentication, encrypted file transfer, and audit logs across all client engagements. For Cayman fund work, we sign confidentiality agreements that align to the manager's existing administrator and custodian terms, and we have processes that align with FATCA, CRS, and GDPR data handling expectations.
Our Cayman-linked work concentrates on industries that drive Cayman activity: alternative investment funds (hedge funds, private equity, venture capital, credit, structured credit), captive insurance and reinsurance, structured finance and insurance-linked securities, holding companies and corporate groups with Indian operating subsidiaries, digital asset and crypto funds regulated under the Virtual Asset (Service Providers) Act 2020, and family offices and private wealth structures. Each industry brings different intersections between Cayman, India, and the home jurisdiction.
Cayman structures rarely sit alone. They pair with operating subsidiaries, parallel funds, and feeder vehicles in other jurisdictions. Explore the markets that connect most often with Cayman engagements.
Planning a Cayman fund with India deployment, restructuring a Cayman holdco above an Indian subsidiary, or raising offshore capital from India through a Cayman vehicle? Speak with our international tax and FEMA team. We will scope the India advisory leg, coordinate with your Cayman counsel, and map the compliance calendar.
Book a 30-minute call with FCA Kapil Mittal or FCA Sachin Jindal. We will review your Cayman and Indian structure, identify Section 9A, FEMA ODI, FPI, and GAAR exposure, and outline a compliance roadmap. Cross-border managers typically leave the call with three concrete next steps.
Download our Cayman Islands business guide covering entity types, fund regimes, the Section 9A safe harbour, FEMA ODI for Indian sponsors, and the India compliance calendar for FPIs and AIF Cat-II vehicles linked to Cayman.
ISO 27001: Information security management system certified.
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Experienced team: 100+ professionals across India, USA, Bangladesh, UAE.
India Office: 0120 4415477-78
WhatsApp: +91-9891576441
Email: info@vjmglobal.com
Website: www.vjmglobal.com
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