UAE, Saudi Arabia, Hong Kong, US, BVI, Panama or Seychelles? Choosing a jurisdiction for your Indian business
The right jurisdiction depends on where your customers are, whether you need visas and banking, and who in India is investing. A side-by-side comparison and three deciding questions.
Indian founders often ask which country is "best" for a company abroad. There is no single answer — but three questions narrow it down quickly, and India's own rules rule out some structures before the comparison even starts.
Question 1 — where are your customers?
- The Gulf, Africa, or worldwide services: the UAE, with Saudi Arabia added when Saudi contracts justify it.
- The Saudi market or Saudi government projects: a Saudi company — and possibly a regional headquarters there.
- Asian supply chains: Hong Kong.
- US customers, platforms and marketplaces: a US LLC.
- Latin America: Panama, after weighing its EU listing.
Question 2 — do you need residence, staff or a local bank account?
The UAE and Saudi Arabia offer residence visas linked to the company and a local banking market. Hong Kong offers banking but company-linked residence is not automatic. BVI, Panama and Seychelles companies generally bank abroad and do not provide residence.
Question 3 — who is investing?
For a resident individual, India's Overseas Investment Rules allow investment only in an operating foreign entity that is not in financial services and has no subsidiary the individual controls. That generally rules out a pure holding company for a resident individual. NRIs investing from foreign funds and Indian companies have more flexibility. See our ODI checklist.
The comparison
| Jurisdiction | Headline tax | Treaty with India | Annual essentials |
|---|---|---|---|
| UAE | 0% up to AED 375,000 taxable income, 9% above; free zone 0% on qualifying income if conditions are met | DTAA | Corporate Tax return; VAT returns if registered |
| Saudi Arabia | 20% income tax on the foreign-owned share; Zakat on Saudi/GCC share | DTAA | Tax/Zakat returns, VAT, annual CR confirmation |
| Hong Kong | 8.25% / 16.5% on Hong Kong-sourced profits | DTA | Audit, profits tax return, annual return |
| US LLC | Federal tax on effectively connected income; state fees | DTAA | Form 5472 with pro forma 1120 (single-member, foreign-owned) |
| BVI | No tax on profits or gains | TIEA only | Annual return to agent; substance; Registry filings |
| Panama | Territorial; from FY 2027, substance requirements for foreign passive income of multinational-group entities | None | Franchise tax; records to resident agent |
| Seychelles | Territorial business tax | TIEA only | Accounting records kept in Seychelles |
For every jurisdiction, a resident Indian investor also files Form FC through the bank before the investment is made, an Annual Performance Report generally by 31 December each year and, if resident and ordinarily resident, Schedule FA in the income tax return.
Where to start
For many Indian businesses with Gulf or international customers, the UAE is a practical first step — our colleagues handle UAE business setup and UAE tax and accounting packages. For anything else, see our jurisdiction comparison or ask a partner.
Sources: See the individual jurisdiction articles for the instruments relied on; Foreign Exchange Management (Overseas Investment) Rules, 2022 and Regulations, 2022; Foreign Exchange Management (Overseas Investment) Directions, 2022, as amended; India's tax treaties with the UAE (1992), Saudi Arabia (2006), Hong Kong (2018) and the USA (1989); India–BVI TIEA (2011); India–Seychelles tax information exchange agreement (in force 2016).