Step-Down Subsidiary Review (ODI)
A step-down subsidiary is an overseas entity held indirectly by an Indian company through another overseas entity it already invests in under the ODI route. Layered structures multiply APR, FEMA/OI Rules, round-tripping and indirect-transfer risk — our review maps the full chain and gives you a clear remediation roadmap.
What's Included
Mapping of the full overseas structure — entities, shareholding, funding flows
Form ODI history reconciliation across all layers
APR coverage check for every JV / WOS in the chain
FLA Return and downstream investment notification review
Round-tripping and indirect-transfer risk assessment
Valuation and inter-company pricing exposure review (incl. transfer pricing)
Risk register with severity rating
Prioritised remediation roadmap and timeline
Our Process
Collect ODI filings, APRs, FLA returns, valuation reports and group structure.
Week 1
Build the full ODI / step-down chart with shareholding and funding flows.
Week 1–2
Test APR coverage, downstream notifications, FLA and supporting documentation.
Week 2
Flag round-tripping, indirect-transfer, valuation and transfer pricing exposure.
Week 2–3
Deliver findings, risk register and prioritised remediation roadmap.
Week 3
Documents Required
- Group structure chart and shareholding details for all overseas entities
- Form ODI submissions (Part I / II / III) for each layer
- Latest APRs for every overseas JV / WOS
- Most recent FLA Return
- Valuation reports and inter-company agreements
Frequently Asked Questions
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