ODI • Step-Down Subsidiary Review

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

STEP 1
Information request

Collect ODI filings, APRs, FLA returns, valuation reports and group structure.

Week 1

STEP 2
Structure mapping

Build the full ODI / step-down chart with shareholding and funding flows.

Week 1–2

STEP 3
Compliance review

Test APR coverage, downstream notifications, FLA and supporting documentation.

Week 2

STEP 4
Risk assessment

Flag round-tripping, indirect-transfer, valuation and transfer pricing exposure.

Week 2–3

STEP 5
Report & roadmap

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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