The short answer
- Most expensive mistakes are made before incorporation: the wrong year end, the wrong directors, the wrong reporting framework.
- Substance is built from day one or argued about later.
- Two countries, two calendars: assume nothing is shared unless you share it.
At incorporation
- Choosing a calendar year end by default. The Indian parent closes on 31 March. A December year end means special-purpose accounts every year. Choose deliberately.
- A nominee director as the whole plan. Legal for incorporation, not enough for a certificate of residence for a holding company, and weak evidence against POEM. Read the options.
- Remitting before Form ODI. The bank filing comes first. Fixing it afterwards costs fees and time. ODI step by step.
- Adopting SFRS(I) without thinking. An unlisted intermediate holding company may lose its consolidation exemption. See the framework choice.
- Leaving Corppass to whoever is around. One administrator who then leaves locks the company out of IRAS and ACRA. Set up two.
In the first year
- Opening the bank account last. It is usually the slowest step. Start in parallel with incorporation.
- No intercompany agreement. Services start, invoices follow, and transfer pricing is reconstructed later. Sign first.
- Running the board by email from India. Every approval from India is POEM evidence. Use a delegation matrix.
- Assuming the start-up tax exemption applies. A wholly corporate-owned subsidiary usually fails it. Check the conditions.
- Assuming no audit is needed. The whole group must pass the small company test, and a large Indian parent usually does not. Run the test.
Every year after
- Two calendars, no owner. APR, FLA, master file and the Singapore annual return all depend on the same numbers. Use one calendar.
- Forgetting master file Part A. It has no threshold for Indian constituent entities. Check your group.
- Claiming treaty rates without a current COR and Form 41. Certificates cover a set period. Renew every year.
- Letting the S$200,000 test slide. Below that annual spend, the company is deemed a shell for treaty capital gains. Track it.
- Nobody keeps the evidence. Minutes, travel, payroll and contracts, filed by year. Five years later, it is the only thing that counts.
A 30-day plan before you incorporate
- Week 1: structure, investors, year end and reporting framework agreed
- Week 2: directors, secretary, registered office and Corppass administrators named
- Week 3: Indian board approval, ODI documents, bank account application started
- Week 4: intercompany agreements drafted, authority matrix approved, two-country calendar built
Which ones cost the most
Three of the fifteen account for most of the clean-up work we see. A nominee director standing in for real management, because it undermines both the certificate of residence and the POEM position at once. Remitting before Form ODI, because regularising it with the bank takes months and blocks further investment. And no intercompany agreement, because every year without one makes the transfer pricing harder to defend in both countries. Fix those three at the start and most of the others become routine calendar items.
Questions people ask
What is the most common mistake Indian groups make in Singapore?
Decisions made by default at incorporation: a calendar year end that does not match the Indian parent, a nominee director as the whole substance plan, and remitting money before Form ODI.
What should be done before incorporating?
Agree structure, year end and reporting framework; name directors, secretary and Corppass administrators; start the ODI and bank processes; and draft intercompany agreements and an authority matrix.
Planning a Singapore entity?
A one-hour planning session covers year end, directors, framework, ODI and the two-country calendar before you incorporate.
Sources
- ACRA: Submitting your application to set up a local company
- ACRA: Audit exemptions and the small company concept
- IRAS: Applying for a certificate of residence
- RBI: Master Direction, Overseas Investment (updated 1 April 2026)
- CBDT Circular 6 of 2017, POEM guiding principles (reproduced) (secondary source)
- Treelife: Master file and CbCR in India, old and new forms (secondary source)
General information only, last reviewed 11 November 2026. It is not advice for your situation. Laws and practice change, and the official sources linked above prevail. Speak to a qualified adviser before you act. Northwise does not file with Indian authorities; India-side work is done by independent licensed firms.
