I attended the 18th BRICS Summit in New Delhi on 12 and 13 September. The most commercially relevant message was the demand for investment that establishes local capacity, strengthens supply chains, transfers technology and creates value within the participating economies.
For a company considering India as its next manufacturing, technology or services base, the UAE may matter to the transaction as much as India does. India provides scale, talent and operating capacity. The UAE can provide capital, coordination, connectivity and international reach.
BRICS has not created a common market or automatic investment rights. What it has done is strengthen the policy direction towards local manufacturing, technology cooperation, resilient supply chains and cross-border investment. Within that direction, India and the UAE offer complementary advantages.
India: Build, Innovate and Scale
India's message at the BRICS Business Forum was commercially direct: "Make in India, Innovate with India, Scale for the World."
This reflects the direction of India's wider investment policy. Access to its large consumer market remains attractive, but international businesses are increasingly expected to establish manufacturing, research and development, local sourcing, employment and export capacity.The summit highlighted opportunities in shipbuilding, semiconductors, critical minerals, biotechnology, artificial intelligence, green hydrogen, batteries, healthcare, digital infrastructure and logistics. Initiatives such as the BRICS Incubator Network, MSME Portal and Startup Innovation Fund are also intended to connect businesses with markets, technology and capital.
India should therefore be considered not merely as a destination for selling products, but as an operating base from which companies can serve domestic and international markets.
The UAE: Capital, Coordination and Connectivity
The UAE offers a different but complementary proposition. It has established itself as a centre for investment, finance, logistics and the international coordination of business.
Depending on the circumstances, an international group investing in India may use the UAE as a regional headquarters, investment or holding platform, treasury function, technology centre, distribution operation or management-services base. The UAE can also connect Indian operations with customers, investors and projects across the Gulf, Africa and other international markets. Its financial centres, free zones, ports, aviation network and expanding range of economic partnership agreements support this role. The UAE's focus on advanced industry, artificial intelligence, renewable energy, food security, infrastructure and logistics also corresponds with many of the sectors being promoted in India.
In July 2026, the Adani Group and Abu Dhabi's International Holding Company (IHC) signed a memorandum of understanding for an integrated aluminium project in Odisha valued at approximately US$11.5 billion, with a projected 53,500 jobs. The arrangement remains at memorandum stage, but it illustrates the model: UAE capital and international connectivity combined with Indian resources, industrial capacity and market scale.
Structuring the India–UAE Opportunity
The commercial logic of using India and the UAE together may be clear, but the transaction structure should not be treated as an administrative issue to be addressed after the investment decision. The location of the parent or holding company can affect financing, governance, taxation, profit repatriation, investor participation and the eventual sale or restructuring of the business. Treaty access and favourable tax treatment cannot be assumed merely because an entity is incorporated in the UAE. The commercial purpose, management, economic substance and actual functions of each entity must support the proposed structure.
The appropriate arrangement is therefore not automatically an Indian subsidiary beneath a UAE holding company. That structure may work well in some transactions, but the decision should follow an assessment of the investors, financing requirements, business activities, regulatory position and intended exit.
The group must also decide which entity will own the intellectual property, raise capital, employ senior management, enter customer contracts, provide services, hold inventory and assume commercial risk. These decisions determine where value is created and where profits should properly arise. They also affect taxation, regulatory responsibility, valuation and the allocation of returns between the UAE and Indian businesses.
From Incorporation to Operation
A company may be legally incorporated but still be unable to receive capital, make payments, employ its team or issue its first invoice.
For the CFO, banking, treasury, foreign-exchange planning, tax registration and payroll are therefore part of the transaction timetable, not post-incorporation administration. Bank-account opening, know-your-customer review and treasury approvals should run alongside incorporation and licensing rather than begin after them.
The method and sequence by which capital enters the business also matter. Equity, shareholder loans, external debt and guarantees can produce different regulatory, tax and repatriation consequences. The financing structure should be agreed before funds are transferred, rather than reconstructed later from accounting records.
A workable implementation plan should bring together incorporation, licensing, banking, funding, tax registration, employment, commercial contracting and compliance reporting, with clear responsibility and realistic timelines for each stage.
Can the Group Explain Where Its Profits Are Earned?
Where UAE and Indian entities operate within the same group, their relationship should be documented before revenue begins. Intercompany agreements may be required for management and technical services, intellectual-property licensing, financing, cost allocation, procurement, distribution and the supply of goods. The allocation of functions, assets and commercial risks in those agreements must correspond with what each entity actually does. Transfer-pricing documentation prepared only after transactions commence can expose the group to later adjustments, penalties and disputes. Similarly, informal contractor, secondment or payroll arrangements may create an unintended taxable presence, employment liability or other regulatory exposure. The legal agreements, operating conduct and accounting treatment must tell the same commercial story.
Capital and Intellectual Property Must Have an Exit Route
- An investment structure is tested not when capital enters, but when an investor wants to sell, repatriate returns or recover its intellectual property. Before capital is committed, investors should determine how shares may be transferred, how the business will be valued and whether put, call, tag-along or drag-along rights are appropriate. They should also consider the regulatory approvals required, restrictions affecting the repatriation of proceeds, and where an exit-related dispute would be resolved and enforced. The same discipline applies to technology and intellectual property. If software, trademarks, processes, technical knowledge or other IP are contributed to an Indian operation, the parties should establish whether ownership is being transferred or merely licensed, who will own improvements and locally developed IP, and what rights will survive termination. Exit rights for capital, technology and intellectual property are substantially easier to establish before deployment than after an investment begins to underperform.
Where the Opportunities Are Likely to Develop
The India–UAE proposition is particularly relevant to international businesses operating in:
- Advanced manufacturing and industrial technology
- Artificial intelligence and digital infrastructure
- Renewable energy, energy storage and smart grids
- Critical minerals, metals and downstream processing
- Ports, aviation, logistics and trade corridors
- Agritech, food processing and food security
- Healthcare, pharmaceuticals and medical technology
- Fintech, investment management and professional services
From Opportunity to Execution
The BRICS Summit has strengthened the commercial case for cross-border manufacturing, technology and investment partnerships. It has not removed the need to structure each transaction according to the laws, regulations and commercial realities of India and the UAE. For boards and investment committees, the central questions are straightforward:
- What value will the investment create in India?
- What genuine commercial function will the UAE entity perform?
- How will capital, revenue and intellectual property move between them?
- Can investors exit and recover value if the plan does not succeed? India and the UAE can work well together within a single investment structure. Whether they do will depend on how that structure is designed, financed, documented, operated and ultimately exited. If your organisation is considering an India–UAE investment, acquisition, joint venture or operating structure, please contact us if you require further information or assistance in structuring, implementing or protecting the transaction.