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Microlesson · 5-min read

Meaning of Foreign Company [Section 2(42), 379, 384, 386]

# Meaning of Foreign Company

## The Two-Element Test

A company qualifies as a foreign company only if BOTH of the following are true:

1. It is a company or body corporate incorporated outside India, AND

2. It:

  • (a) Has a place of business in India (itself or through an agent, physically or through electronic mode), AND
  • (b) Conducts business activity in India.

'Place of business' includes a branch office and a share transfer or registration office.

## Electronic Mode — Wide Definition

Electronic mode includes carrying on electronically (server may or may not be in India):

  • B2B and B2C transactions, Data Interchange, Other Digital Supply Transactions
  • Inviting/Accepting Deposits or subscription of Securities in India or from Indian citizens
  • Financial Settlements, Web-based Marketing, Advisory & Transactional Services, Database services & products, Supply Chain Management
  • Online services (telemarketing, telemedicine, education, information research)
  • All related data communication services

## The Distinguishing Test — Activity vs. Mere Presence

Mere physical presence or meetings in India is NOT enough. There must be business activity in India.

## Provisions Applicable to a Foreign Company (with modifications)

  • Section 128 — Keep Books of Account of Indian business at principal place of business in India.
  • Section 92 — File Annual Return (Form FC-4) with ROC within 60 days of last day of FY.
  • Section 71 (Debentures), Chapter VI (Registration of Charges), Chapter XIV (Inspection, Inquiry, Investigation) — apply mutatis mutandis.

## The 50% Rule — Treated Like an Indian Company

If ≥ 50% paid-up share capital (equity + preference combined) of a foreign company is held by:

  • Indian citizens, OR
  • Company/Body Corporate incorporated in India, OR
  • Both,

then — for its Indian business — such company must comply with Chapter XXII and other prescribed provisions as if it were an Indian company.

Note: Sections 380 to 386, 392 and 393 apply to all foreign companies (regardless of the 50% test).

Worked example

### Example 1

Q. R Ltd., incorporated in Japan, holds its Board meetings and takes business decisions in India but has no office, employees, or activity in India. Is R Ltd. a foreign company?

A. No. Mere holding of BOD meetings and executing decisions in India does not amount to a 'place of business' or 'business activity' in India. R Ltd. is not a foreign company.

### Example 2

Q. RFC Ltd. (Singapore) has a place of business in Mumbai. Total paid-up capital is $4,97,50,000 (Equity $4 cr, Preference $97.5 lakhs). Indian holdings: Mr. R (Indian citizen) holds 26,000 preference shares including 1,100 partly paid (at $50). Ronak Ltd. (Indian) holds 2,23,500 equity shares of $100 each. Is RFC required to comply with Chapter XXII as if Indian?

A. Indian holdings: Mr. R = (26,000 × $100) − (1,100 × $50) = $26,00,000 − $55,000 = $25,45,000. Ronak Ltd. = 2,23,500 × $100 = $2,23,50,000. Total Indian holding = $2,48,95,000. Total paid-up = $4,97,50,000. Ratio = ~50.04% — exceeds 50%. Therefore RFC Ltd. must comply with Chapter XXII and other prescribed provisions as if it were an Indian company in respect of its Indian business.

⚠️ Common exam mistakes

  • Treating any foreign-incorporated company with any Indian presence as a foreign company — business activity in India is essential.
  • Calculating the 50% based on equity only — it is on TOTAL paid-up capital (equity + preference).
  • Computing paid-up capital on shares using face value when shares are only partly paid — only the actually paid amount counts.
  • Confusing place of business (branch, share transfer office) with mere meeting locations.
  • Assuming the 50% rule replaces all foreign-company provisions — Sections 380 to 386, 392 and 393 still apply.
Bare-Act text Section 2(42) · Companies Act, 2013 · click to expand
'foreign company' means any company or body corporate incorporated outside India which—(a) has a place of business in India whether by itself or through an agent, physically or through electronic mode; and (b) conducts any business activity in India in any other manner.
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