GST Registration in India for Irish Companies

GST Registration for Irish Companies in India

India and Ireland share a rapidly growing economic partnership, with bilateral trade (goods and services) reaching approximately EUR 16 billion in 2023 — a 60% increase from 2021. Business between the two countries has grown by 90% over the past decade, and projections suggest it will touch EUR 20 billion by 2026. In March 2025, India and Ireland agreed to establish a Joint Economic Commission to further boost trade and investment, with collaboration deepening across pharmaceuticals, technology, AI, fintech, cybersecurity, and semiconductors.

Major Irish companies including CRH, Diageo, Kerry Group, ICON plc, Glanbia, and Globoforce maintain significant operations in India, primarily in technology, pharmaceuticals, food ingredients, and business services. Ireland's position as a European technology and pharmaceutical hub makes it a natural partner for India's growing economy.

For every Irish company conducting taxable business in India — whether through a Wholly Owned Subsidiary (WOS), Branch Office, Liaison Office, or project-based engagement — obtaining GST registration is a mandatory prerequisite before making taxable supplies. Unlike domestic Indian businesses that enjoy turnover-based exemptions (INR 40 lakh for goods, INR 20 lakh for services), foreign entities from Ireland are generally required to register for GST regardless of revenue.

This guide covers the complete GST registration process for Irish companies, including how the India-Ireland DTAA interacts with GST, the specific documents needed from the CRO and Revenue Commissioners, timelines, costs, and compliance challenges unique to Irish businesses operating in India.

How Ireland's DTAA Affects GST Registration

The India-Ireland DTAA, which came into force on December 26, 2001, governs the taxation of cross-border income between the two countries. In India, it covers income tax including surcharge; in Ireland, it covers income tax, corporation tax, and capital gains tax. The treaty provides a uniform 10% withholding tax rate across most income categories — one of the most favorable rates in India's DTAA network.

However, the DTAA applies exclusively to direct taxes (income tax, corporation tax, capital gains tax). GST, being an indirect consumption tax, falls entirely outside the treaty's scope. Irish companies cannot use DTAA provisions to reduce or defer their Indian GST liability.

Key DTAA Rates (Income Tax Only)

• Dividends (Article 10): 10% withholding — lower than India's domestic rate of 20%
• Interest (Article 11): 10% withholding on interest payments between the two countries
• Royalties (Article 12): 10% withholding on royalty and technology licensing payments
• Fees for Technical Services (Article 12): 10% withholding — substantially lower than the domestic 20% rate, particularly beneficial for Irish tech companies providing services to Indian subsidiaries
• Permanent Establishment (PE): An Irish company with a fixed place of business in India, a building site exceeding 183 days, or a dependent agent can create a PE, triggering full income tax and mandatory GST registration

To claim these DTAA benefits, Irish companies must obtain a Tax Residency Certificate from the Irish Revenue Commissioners and file Form 10F with Indian tax authorities. These DTAA benefits apply to direct tax only — GST obligations exist independently.

India-Ireland Joint Economic Commission

In March 2025, India and Ireland agreed to establish a Joint Economic Commission (JEC), marking a significant step in formalizing bilateral economic cooperation. The JEC will focus on expanding collaboration in higher education, emerging sectors (AI, fintech, cybersecurity, semiconductors), and trade facilitation. While this institutional framework will enhance business connectivity, it does not modify domestic GST rates or registration requirements. GST compliance in India remains governed entirely by the CGST and SGST Acts.

Document Requirements from Ireland

Both Ireland and India are members of the Hague Apostille Convention. Irish documents can be authenticated via apostille issued by the Department of Foreign Affairs and Trade in Dublin. This is significantly faster and simpler than embassy attestation, and apostilled Irish documents are accepted directly in India without further diplomatic legalization.

Documents Required

• CRO (Companies Registration Office) Certificate — Certificate of Incorporation or company extract from the CRO (apostilled)
• Company Registration Number — CRO number
• Board Resolution authorizing GST registration in India (notarized and apostilled)
• Passport and Indian business visa of the authorized signatory
• PAN card of the authorized signatory or Indian entity
• Proof of Indian business address — rental agreement, utility bill, or property tax receipt
• Indian bank account details — cancelled cheque or recent bank statement
• Photographs of the authorized signatory
• Tax Residency Certificate from the Irish Revenue Commissioners — required for DTAA benefits, often requested as supporting documentation

Apostille Process in Ireland

The Department of Foreign Affairs and Trade is the designated Competent Authority for issuing apostilles in Ireland. Applications can be submitted by post or in person at the Consular Section in Dublin. Processing typically takes 3-5 business days for standard service. The fee is EUR 20 per document for postal applications. Apostilles can only be applied to public documents — the CRO certificate and notarized board resolutions qualify. For a comparison of authentication methods, see Apostille vs. Embassy Attestation.

Step-by-Step GST Registration Process

Option A: NRTP Registration (No Indian Entity)

If an Irish company wants to make taxable supplies in India without establishing a permanent entity, it can register as a Non-Resident Taxable Person (NRTP):

1. Apply at least 5 days before starting business — Submit Form GST REG-09 on the GST portal
2. Appoint an authorized signatory — Must be a resident Indian with a valid PAN and Indian mobile number
3. Submit apostilled CRO documents — Certificate of Incorporation, board resolution, signatory passport
4. Pay the mandatory advance deposit — Amount equal to estimated GST liability for the 90-day registration period
5. Receive Temporary Reference Number (TRN) — Generated automatically after payment confirmation
6. Complete Part B — Upload supporting documents, provide Indian address, sign with DSC
7. GSTIN issued — Valid for 90 days, extendable once for another 90 days

Option B: Regular Registration (Via Indian Subsidiary or Branch)

1. Establish the Indian entity — Obtain Certificate of Incorporation and PAN from MCA
2. Access the GST portal — Navigate to Services, then Registration, then New Registration
3. Complete Part A — Enter PAN, email, and mobile number for OTP verification
4. Complete Part B — Business details, principal place of business, bank account, authorized signatory
5. Upload documents — PAN, address proof, MoA, board resolution, apostilled CRO certificate
6. Submit with DSC — Digital Signature Certificate is mandatory for companies
7. GSTIN allotted in 3-7 working days — Under GST 2.0, auto-approval can process applications in 3 days

Timeline and Costs for Irish Companies

Timeline Breakdown

Cost Breakdown

Common Challenges for Irish Companies

1. Ireland's VAT vs India's GST — EU System vs Indian Framework

Ireland operates within the EU VAT framework with a standard rate of 23%, along with reduced rates (13.5%, 9%, 4.8%) for specific categories. The EU VAT system features a single registration for intra-EU sales (OSS mechanism), quarterly filing, and harmonized rules across 27 member states. India's GST is a multi-slab structure (5%, 12%, 18%, 28%) with the split between CGST, SGST, and IGST, monthly filing requirements, e-invoicing mandates, and mandatory state-wise registration. Irish companies accustomed to the relatively streamlined EU VAT system must adapt to India's more granular compliance framework with significantly higher filing frequency.

2. Technology and Pharmaceutical Transfer Pricing

Many Irish companies set up Indian operations as technology development centers, pharmaceutical R&D hubs, or shared service centers. The transfer pricing of intercompany transactions — royalties, licensing fees, management charges, and R&D cost-sharing — must reflect arm's length margins under both Indian and Irish tax law. While transfer pricing relates to income tax, the pricing of intercompany services also determines the GST-assessable value. Indian tax authorities have been particularly vigilant about technology and pharmaceutical services, making robust benchmarking essential.

3. Fiscal Year Mismatch

Ireland follows the standard January-December calendar year for most companies (though companies can choose their fiscal year end), while India mandates April-March. This creates reconciliation challenges for consolidated reporting. Irish parent companies need their Indian subsidiaries to provide quarterly consolidation data aligned to the Irish fiscal calendar, while simultaneously meeting Indian statutory deadlines based on the April-March year.

4. EU Data Protection and Indian GST Portal Requirements

Irish companies operating under GDPR (EU General Data Protection Regulation) may have concerns about uploading corporate documents, director details, and financial information to Indian government portals. The GST portal requires disclosure of director passport details, Indian address, and financial projections. Companies should ensure their GDPR compliance frameworks account for legitimate regulatory requirements in India and document the legal basis for such data transfers.

5. EUR-INR Exchange Rate Volatility

The Euro-Rupee exchange rate directly affects the GST-assessable value of imported goods and intercompany transactions. Indian customs uses the exchange rate notified by the CBIC on the date of filing the Bill of Entry, which may differ from the commercial rate used in invoicing. Irish companies with significant import volumes must reconcile these valuation differences carefully to avoid GST underpayment or overpayment issues.

Why Choose BeaconFiling

BeaconFiling has experience supporting Irish and European companies navigating India's GST and compliance landscape. We handle everything from apostille coordination to GST portal submission, ongoing GST return filing, and FEMA/RBI compliance. Our services also include transfer pricing documentation particularly relevant for technology and pharmaceutical companies, and annual compliance management. Visit our Ireland country page for more on establishing operations in India from Ireland.

Frequently Asked Questions