India platform

A repeatable platform for India’s landmark observation wheels.

Starneth India’s proposed multi-city platform separates national strategy, technical collaboration and city-specific project risk while allowing every Eye to express the identity of its location.

A proposed structure, subject to tender, legal, tax, procurement, lender and regulatory review. Exact ownership and consortium composition must be tested against each tender.

The network

Six cities, plotted.

A coordinate frame rather than a map. Each node links to that city's concept direction; the centre node is the proposed national platform layer.

The platform model

One ownership chain. One technical chain. No crossing between them.

Select any node to read what it does. The six city project companies are drawn as separate boxes because that is the point of the structure: each one carries its own concession, financing and risk, and none of them reaches the parent.

Technical chain

No direct Juma equity, beneficial ownership or permanent ownership tie with Starneth India or MasterCo under the recommended structure.

Protected parent company

Starneth India Private Limited

Holds the Indian brand, strategy, pipeline and group control. Owns MasterCo, approves group strategy and major investments, receives dividends and monitors governance. It is deliberately kept out of city-level concessions, investor admissions and project guarantees.

Clear role separation

Each company has a distinct purpose, contracts and risk boundary.

The liability separation works only if guarantees, collateral, cash and contracts are not mixed across companies. That is a discipline, not a diagram.

Protected parent

Starneth India

  • Owns and controls MasterCo.
  • Approves group strategy and major investments.
  • Controls the Indian brand, pipeline, domains and strategic intellectual property.
  • Receives dividends and monitors governance.
  • Should not automatically admit city investors.
  • Should not sign every concession.
  • Should not guarantee every city debt.
National operating platform

MasterCo

  • Signs the proposed India-wide collaboration agreement with Starneth B.V.
  • Identifies opportunities and prepares bids.
  • Leads consortiums where appropriate and forms city SPVs.
  • Provides development and management services.
  • Holds controlling stakes where each tender permits.
  • Should not centralise all project investors.
  • Should not borrow all project debt centrally.
One project, one risk boundary

City SPV

  • Signs the concession, land lease, financing, escrow, EPC and O&M agreements.
  • Receives city-specific equity and debt.
  • Pays applicable lease, premium and concession charges.
  • Builds, operates and earns revenue from that city project.
  • Carries that project's construction, operational, lender and termination risks — and only that project's.
Starneth B.V. to Juma

Technical chain

  • Starneth B.V. acts as the accountable technical counterparty under the proposed structure.
  • Juma remains the OEM and manufacturer under Starneth B.V.
  • Direct OEM letters, warranties, registrations and experience documents may still be needed where tenders require them.
  • Juma does not receive automatic Indian ownership or group control rights.

Parent equals ownership and brand. MasterCo equals national development and coordination. City SPV equals city contracts, finance and project risk.

Why create MasterCo

The benefit is control, repeatability and risk separation.

MasterCo is not legally mandatory. It becomes commercially sensible once there are multiple projects, multiple cities and multiple investors — and it has to be justified by business substance rather than by tax.

No sugar-coating

Commercial discipline, not a tax shortcut.

A useful structure still needs disciplined compliance and arm's-length documentation. The figures below are planning allowances, not quotations, and not advice.

Column A

Cost to operate MasterCo

  • One-time incorporation, legal, banking, tax and intercompany setup.
  • Annual audit, ROC filings, tax return, GST, payroll and board compliance.
  • Cross-border transfer-pricing documentation, withholding and treaty review for Starneth B.V. fees.
  • Planning estimate: approximately ₹4–10 lakh annually for a simple active MasterCo.
  • Planning estimate: approximately ₹10–25 lakh or more annually for a multi-SPV, cross-border platform.
  • These are planning estimates, not statutory quotations.
Column B

Potential tax treatment

  • Section 115BAA may offer a 22 per cent base corporate tax rate plus applicable surcharge and cess, subject to conditions.
  • Section 80M may reduce qualifying dividend cascading when statutory conditions and timelines are met.
  • MasterCo may retain post-tax cash and reinvest it into city SPVs.
  • An individual SPV stake may be sold without selling the entire Indian platform, although capital-gains tax may apply.
Column C

What MasterCo does not provide

  • No automatic tax holiday.
  • No general group-loss consolidation — one SPV's loss normally cannot simply offset another SPV's profit.
  • Management and licence fees may attract GST, TDS and transfer-pricing review.
  • Artificial fee shifting or undocumented related-party charges create tax and lender risk.
Regulatory watch

Keep MasterCo operationally active

A company that becomes a mainly passive holder of group investments can attract Core Investment Company analysis. MasterCo should perform real development and management functions, and that should be reviewed annually.

Regulatory watch

Disclose the actual OEM

Zero equity does not remove disclosure duties. Disclose the actual OEM or supplier whenever tender, procurement, lender or regulatory rules require it, and obtain direct OEM letters or registrations where the RFP demands them.

Reviewed 2026-08-28The structure is a planning concept. Final implementation requires company-specific legal, tax, tender and regulatory advice.

Consortium model

Use the smallest consortium that satisfies the RFP.

Keep permanent group ownership separate from project investors, and add a member only when the tender actually requires what that member brings.

  1. 01MasterCoPreferred lead memberWhere tender conditions permit.
  2. 02Starneth B.V.Technical memberOnly when its credentials are required.
  3. 03City financial partnerConsortium memberOnly when its net worth, land, funding or eligibility is relied upon.
  4. 04JumaOEM or subcontractorDirect consortium participation only where the tender requires it.

Do not make introducers, liaison partners or local facilitators consortium members unless the tender genuinely requires their eligibility, land or funding.

Fifteen guardrails

The rules that keep the structure worth having.

  1. 01Keep Starneth India with its existing promoters.
  2. 02Create MasterCo as a wholly owned subsidiary initially.
  3. 03Give city investors ownership only in their relevant city SPV.
  4. 04Give Juma no automatic Indian equity, beneficial ownership, board or control rights.
  5. 05Keep MasterCo in control of each SPV where tender conditions permit.

Explore partnership opportunities on a specific city.