Foreign Companies - Procedures for Opening Branches in India Under Companies Act and FEMA

Companies Incorporated Outside India:directorships, particulars of that directorship or of some
Right from days of East India Company foreignone of those directorships; and
companies were incorporating companies in India. After(ii) in the case of a body corporate, its corporate name
the liberalization policy Indian companies also startedand registered or principal office; and the full name,
incorporating subsidiaries outside India. Recently manyaddress, nationality, and nationality of origin, if different
foreign companies have shown interest to openfrom that nationality, of each of its directors;
branch office or liaison office to monitor their business(b) with respect to the secretary, or where there are
in India. In case they opt to incorporate a subsidiaryjoint secretaries, with respect to each of them -
company in India they have to follow the procedures(i) in the case of an individual, his present name and
given under the Companies Act, and also thesurname, any former name or names and surname or
provisions of the act will apply in to after the companysurnames, and his usual residential address; and
is incorporated. If a company incorporated outside India(ii) in the case of a body corporate, its corporate name
wish to have a place of establishment in India withoutand registered or principal office :
incorporating separate company for various reasonsProvided that, where all the partners in a firm are joint
then it has to follow the procedures laid down in Partsecretaries of the company, the name and principal
XI-sections 591 to 602.office of the firm may be stated instead of the
The Act, which has been enacted to oversee theparticulars mentioned in clause (b) of this sub-section.
functioning of companies in India, draws heavily from(3) Clauses (2) and (3) of the Explanation to
the United Kingdom's Companies Acts and althoughsub-section (1) of section 303 shall apply for the
similar, is more comprehensive. The Registrar ofpurpose of the construction of references in
Companies (ROC) and the Company Law Boardsub-section (2) to present and former names and
(CLB), both working under the Department ofsurnames as they apply for the purposes of the
Company Affairs, ensure compliance with the Act.construction of such references in sub-section (1) of
Sections 592 to 602 of the Companies Act of Indiasection 303.
closely follows sections 406 to 423 of the English Act(4) Foreign companies, other than those mentioned in
barring sections 408, 416 to 418 of the act.sub-section (1), shall, if they have not delivered to the
Foreign Companies:Registrar before the commencement of this Act the
A foreign company is a company which isdocuments and particulars specified in sub-section (1)
incorporated in a country outside India under the law ofof section 277 of the Indian Companies Act, 1913 (7 of
that other country and has a place of business in India.1913), continue to be subject to the obligation to deliver
Sections 591 to 602 of the Act deal with suchthose documents and particulars in accordance with
companies.that Act.
Foreign Companies are of two classes namely:When any change occurs in the above particulars, the
Companies incorporated outside India, which haveRegistrar must be intimated accordingly. According to
established a place of business in India after April 1,section 596 any process, notice, or other document
1956; andrequired to be served on a foreign company shall be
Companies incorporated outside India, which havedeemed to be sufficiently served, if addressed to any
established a place of business in India before thatperson whose name has been delivered to the
date and continue to have an established place ofRegistrar under the foregoing provisions of this Part
business in India.and left at, or sent by post to, the address which has
Part XI of the Companies Act, 1956 containing Sectionbeen so delivered:
591 to 608 deals with the Companies incorporatedProvided that -
outside India i.e. a "Foreign Company." The provisions(a) where any such company makes default in
of this part of the Companies Act, 1956 prescribesdelivering to the Registrar the name and address of a
that its Sections 592 to 602 shall be applicable toperson resident in India who is authorized to accept on
Companies who are incorporated outside India whichbehalf of the company service of process, notice or
after the commencement of the Companies Act, 1956other documents; or
establishes a place of business within India and(b) if at any time all the persons whose names and
Companies incorporated outside India havingaddresses have been so delivered are dead or have
established place of business within India prior to theceased so to reside, or refuse to accept service on
commencement of the Companies Act, 1956 andbehalf of the company, or for any reason, cannot be
continue to have the said establishment. It says that aserved;a document may be served on the company
Company incorporated outside India and having anby leaving it at, or sending it by post to, any place of
established place of business in India in which 50% orbusiness established by the company in India.
more paid up share capital is held by Indians thenThe Indian accounts have to be drawn up in Indian
provisions of those sections shall apply to suchrupees as per the requirements of Schedule VI.
Companies also.Under Regulation 22 of the Companies Regulations,
Sections 592 to 602 applicable to such Foreign1956 the registrar having jurisdiction over Delhi must
companies provide that they have to file with themaintain a Register of Foreign Companies in Form III. In
Registrar of Companies:that the names of foreign companies must be entered
Various documents giving particulars,in the order in which the documents referred to in
Returns regarding any alterations in the company,section 592 of the Companies Act are delivered to
Balance-sheet and Profit & Loss Accounts of thethe Registrar.
company,The company has to address all communication to
Charges on any of the Companies' properties in India.The Registrar of Companies, NCT of Delhi and
It also provides that the following provisions shall applyHaryana.
to Indian business of a Foreign Company:Court's jurisdiction:
Registration of charges,The jurisdiction will be decided with reference to the
Right to obtain copies of and inspect the trust deed,filing of documents and information pursuant to Section
Books of account to be kept by the Company,592. Clause (d) of sub-section (1) requires the foreign
Annual returns to be made by the Company,companies to furnish particulars about the names and
Inspection of books of accounts,addresses of some persons on whom notices can be
Power of Central Government to direct special audit,served insofar as the foreign company is concerned.
Audit of cost accountants,In the case of amalgamation of branch of a foreign
Power of Registrar to call for inspection andcompany in India with the transferee company
investigationjurisdiction of High Court for sanctioning under section
(Contained in Sections 124 to 145, 125, 127, 118, 209, 159,391/394 read with section 591 and 597(1) it is the
209-A,, 233-A, 233B, and 234 to 246 of thejurisdiction of registered office or place of business
Companies Act)which would decide the jurisdiction of any High Court
Section 603 of the said part XI puts certain restrictionto entertain the petition for approval of amalgamation
on a foreign company offering documents forscheme under section 391/394 and not Delhi. [Bank of
subscriptions in India.Muscat S.A.O.G, In re. (2004) 60 CLA 325 (Kar.)]
Though under the Companies Act, 1956, no formalitiesEstablishment of Place of Business in India- FEMA
are required to be carried out for a Foreign CompanyRequirements:
establishing place of business in India except the filingThe Foreign Exchange Management Act, 1999(FEMA)
of the documents provided for in Part XI; under thehas framed Regulations relating to establishing any
provisions of Section 29 of the Foreign Exchangeplace of business in India. The Foreign Exchange
Regulation Act, 1973 general or special permission ofManagement (Establishment in India of Branch or
the Reserve Bank of India for continuing any place ofOffice or other place of business) Regulations, 2000
business or establishing any place of business for(Regulations) provides for establishment by a
carrying on activities of trade and Commercial naturenon-resident any place of business, which would be a
by a foreign company is required.Liaison office or Project office or site office or branch
General:office.
The limit of the foreign equity in an Indian Company isIn terms of the Regulation the following two points are
now increased up to 51% from the earlier 40%. Innoteworthy:
certain cases 100% foreign equity participation is alsoNo person resident outside India shall, without prior
now allowed. The Government of India has enteredapproval of the Reserve Bank establish in India any
into agreements with major foreign countries includingplace of business-be it branch or a liaison office or a
USA for avoiding double taxation.project office or any other business by whatever
Section 592 merely deals with the requirements ofname called.
filing various documents and information with theCitizens of Pakistan, Bangladesh, Sri Lanka,
Registrar of Companies. The Registrar, for theAfghanistan, Iran or China cannot establish any place
purpose of this section, is the Registrar of Companies,of business- be it branch or a liaison office or a project
Delhi and also the Registrar of Companies of theoffice or any other business by whatever name called,
State in which the place of business is situated. Theunless they procure RBI permission in this regard.
filing has to be done within 30 days of thePlace of Business-what they are?:
establishment of the place of business. ForeignThe Regulations define various place of business as
companies are required to file one set of documentsunder-
with the Registrar of Companies, Delhi and the other'Liaison Office' means a place of business to act as a
set of documents with the Registrar of Companies ofchannel ofcommunication between the Principal place
the State in which the company has established itsof business or Head Office bywhatever name called
place of business. Filing fee of Rs. 5000 has to be paidand entities in India but which does not undertakeany
only at ROC Delhi and no filing fee be paid for filingcommercial /trading/ industrial activity, directly or
copy with the other ROC.indirectly, andmaintains itself out of inward remittances
If the company establishes any branch or branches ofreceived from abroad throughnormal banking channel.
its business in India, no further information need be'Project Office' means a place of business to
given, except that with the annual accounts therepresent the interests of theforeign company
company should deliver three copies of a list of all itsexecuting a project in India but excludes a Liaison
places of business in India and with reference to whichOffice.
the accounts are made out.'Site Office' means a sub-office of the Project Office
Every foreign company must conspicuously exhibit onestablished at thesite of a project but does not include
the outside of its every office or place of business ina Liaison Office.
India its name ending with the words "Limited" orThus, while a Liaison office is only a channel for
"Private Limited", as the case may be, if it is limitedfacilitating communication between the principal entity
company, and the country of its incorporation in Englishabroad and that in India, existing without any
as well as in the local language.commercial activity the Project office is one for
Where a foreign company carries on its business inexecuting specific projects in India. A Site office is an
India through an agent, the agent is required to complyextension of project office in the very site where the
with the provisions of this section (592).work is done.
A company shall be said to have a place of business"Branch office", in relation to a company means -
in India if it has a specified or identifiable place at which(a) any establishment described as a branch by the
it carries on business such as an office, store house,company; or
go down or other premises having some concrete(b) any establishment carrying on either the same or
connection between locality and its business.substantially the same activity as that carried on by
594. ACCOUNTS OF FOREIGN COMPANY.the head office of the company; or
The provisions concerning the accounts of a foreign(c) any establishment engaged in any production,
company are detailed in section 594. It lays down theprocessing or manufacture,but does not include any
general obligation - once in every calendar year toestablishment specified in any order made by the
make out a balance sheet and profit and loss accountCentral Government under section 8.
in respect of its Indian business, under the presumptionForms and Procedure:
that it were an Indian company, giving details also of itsA person resident outside India desiring to establish a
subsidiaries and to deliver three copies of thebranch or liaison or project office in India shall apply to
documents to the Registrar. When not in English, athe Reserve Bank in form FNC 1. In respect of Project
certified translation should also be annexed. A list of alloffice, the person resident outside India should have
places of business established by the foreign companysecured from an Indian company a contract to
in India with reference to which the balance sheet isexecute a project in India and the project is funded
made out should also be sent regularly.directly by a bilateral or multilateral International
In other words, the foreign company shall maintainFinancing Agency or the project has been cleared by
books of accounts of its Indian business and file, everyan appropriate authority or a company or entity in India
year, three copies of its world accounts (within nineawarding the contract has been granted term loan by
months from the close of the financial year), Indiana Public Financial Institute or a bank in India for the
business accounts (within nine months from the closeproject.
of the financial year) and a list of places of businessPermitted activities:
established in India.Paragraph 6 of the Regulations sets out the activities
In respect of its Indian business, the foreign company isto be undertaken by a branch or other office in India.
required to maintain at its principal place of business inSchedule I of the regulations details the activities that
India, proper books of accounts with respect to allcan be carried out by Branch and Schedule II list out
sums of money received and expended by thethe activities that can be carried out by liaison office.
company and the matters in respect of which theExcept when permitted by RBI, the branch or liaison
receipt and expenditure take place, all sales andoffice shall carry out no other activity, other than those
purchases of goods by the company, and all assetsspecifically permitted by these schedules.
and liabilities of the companyAs per Schedule I of the Regulations the following are
Where the foreign company sets up a liaison office inthe permitted activities for a branch in India of a person
India, it shall prepare a "statement of receipts andresident outside India:
payments" and a "statement of assets and liabilities"Export/Import of goods
instead of a balance sheet and profit and loss account.Rendering professional or consultancy services.
These shall be in the prescribed form and shall be dulyCarrying out research work, in which the parent
audited, the auditor giving his report as to the truth andcompany is engaged.
fairness of the receipt and payments during thePromoting technical or financial collaborations between
financial yearIndian companies and parent or overseas group
The Government has granted several exemptions andcompany.
made modifications in regard to the above, in the lightRepresenting the parent company in India and acting
of its general policy as to foreign companies.as buying/selling agent in India.
Exemptions are also given to liaison offices. SpecialRendering services in Information Technology and
clarifications are issued in regard to foreign shipping,development of software in India.
airline and insurance companies and also trade andRendering technical support to the products supplied
industrial activities of foreign companiesby parent/group companies.
The documents are to be filed with the RegistrarForeign airline/shipping company.
within a period of nine months of the close of theIn terms of Schedule II a liaison office in India of a
financial year of the foreign company or within suchperson resident outside India is permitted to carry out
period as extended by the Registrar not exceedingthe following activities:
three months.Representing in India the parent company/group
Provisions Relating To Foreign Companies:companies.
(1) Foreign companies which, after the commencementPromoting export import from/to India.
of this Act, establish a place of business within IndiaPromoting technical/financial collaborations between
shall, within thirty days of the establishment of theparent/group companies and companies in India.
place of business, deliver to the Registrar forActing as a communication channel between the
registration -parent company and Indian companies.
(a) a certified copy of the charter, statutes, orRemittance of Profit or Surplus:
memorandum and articles, of the company or otherA person resident outside India permitted by the
instrument constituting or defining the constitution of theReserve Bank under Regulation 5, to establish a
company; and, if the instrument is not in the Englishbranch or Project Office in India may remit outside
language, a certified translation thereof;India the profit of the branch or surplus of the Project
(b) the full address of the registered or principal officeon its completion, net of applicable Indian taxes, on
of the company;production of the following documents, and establishing
(c) a list of the directors and secretary of thethe net profit or surplus, as the case may be, to the
company, containing the particulars mentioned insatisfaction of the authorized dealer through whom the
sub-section (2);remittance is effected.
(d) the name and address or the names andFor remittance of profit of a branch, -a) certified copy
addresses of some one or more persons resident inof the audited balance-sheet and profit and loss
India, authorized to accept on behalf of the companyaccount for therelevant year;b) a Chartered
service of process and any notices or otherAccountant's certificate certifying, -i) the manner of
documents required to be served on the company;arriving at the remittable profit,ii) that the entire
andremittable profit has been earned by undertaking
(e) the full address of the office of the company inthepermitted activities, andiii) that the profit does not
India which is to be deemed its principal place ofinclude any profit on revaluation of the assetsof the
business in India.branch.
(2) The list referred to in clauseFor remittance of surplus on completion of the Project,
(c) of sub-section-certified copy of the final audited Project accounts;a
(1) shall contain the following particulars, that is to say :-Chartered Accountant's certificate showing the
(a) with respect to each director, -manner of arriving at the remittable surplus;income tax
(i) in the case of an individual, his present name andassessment order or either documentary evidence
surname in full, any former name or names andshowing payment of income tax and other applicable
surname or surnames in full, his usual residentialtaxes, or a Chartered
address, his nationality, and if that nationality is not theAccountant's certificate stating that sufficient funds
nationality of origin, his nationality of origin, and hishave been set aside for meeting all Indian tax liabilities;
business occupation, if any, or if he has no businessandauditor's certificate stating that no statutory liabilities
occupation but holds any other directorship orin respect of the Project are outstanding.