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Microlesson · 5-min read

Prohibited Capital Account Transactions & Non-Restrictable Drawals

# Prohibited & Non-Restrictable Capital Account Transactions

## Part A: Transactions on Which Restrictions CANNOT Be Imposed (Proviso to Section 6(2))

RBI/CG cannot restrict drawal of foreign exchange for:

1. Amortisation of loans (i.e., loan repayment installments)

2. Depreciation of direct investments in ordinary course of business

These are treated as inevitable economic obligations and are kept free of restrictions.

## Part B: Prohibited Capital Account Transactions

### (a) USD 250,000 Cap for Residents – with FATF Bar

  • A resident individual may draw foreign exchange not exceeding USD 250,000 per financial year (or such amount as RBI may decide) for any capital account transaction in Schedule I.
  • Para 1 of Schedule III of FEM (CAT) Rules 2000 is subsumed within this USD 250,000 limit.
  • If a Schedule I capital account drawal exceeds USD 250,000, the limit prescribed in the specific regulation governing that transaction applies to the excess.

FATF Bar: No part of this USD 250,000 may be remitted (directly or indirectly) to countries notified as Non-Cooperative Countries and Territories (NCCTs) by FATF and communicated by RBI.

### (b) Prohibited Activities for Non-Resident Investments into India

A person resident outside India is PROHIBITED from investing in any company/firm/proprietary concern/entity (incorporated or not) engaged or proposing to engage in:

#Prohibited ActivityCarve-Out / Note
1Chit fund businessRegistrar of Chits (with State Govt. consent) may permit NRIs to subscribe to chit funds via banking channel on non-repatriation basis, without limit, subject to RBI conditions
2Nidhi companyAbsolute prohibition
3Agricultural or plantation activitiesAbsolute prohibition
4Real estate business OR construction of farm houses'Real estate business' excludes: development of townships, construction of residential/commercial premises, roads or bridges (these are permitted)
5Trading in Transferable Development Rights (TDRs)Absolute prohibition

### (c) North Korea (DPRK) Restriction

  • No person resident in India may undertake any capital account transaction with a citizen, resident, or entity of the Democratic People's Republic of Korea, except as permitted under Order S.O. 1549(E) dated 21 April 2017 of the Ministry of External Affairs, OR with specific Central Government approval.

### (d) Winding Down Existing DPRK Exposure

  • Any existing investments, representative offices, or other assets in DPRK held by Indian residents — which are not permitted under the said MEA Order — must be closed/liquidated/disposed/settled within 180 days from the date of the relevant Notification, unless specifically approved by the Central Government.

## Crucial Closing Principle

> A capital account transaction is permitted ONLY if it is specifically permitted under the regulations. If a transaction is NOT generally permitted, a prior specific approval is required.

This is the opposite of the rule for current account transactions (which are generally permitted unless prohibited).

## Quick Recap Table

CategoryRule
No restriction allowedLoan amortisation; depreciation of direct investment
Cap for resident individualsUSD 250,000 per FY
FATF non-cooperative countriesNo remittance from the USD 250,000
Non-resident investment banChit fund (NRI carve-out), Nidhi, agriculture/plantation, real estate business / farm houses, TDR trading
DPRKProhibited; existing exposure to be wound up in 180 days

Worked example

### Example 1

Example 1: Mr. C, a resident individual, wishes to remit USD 300,000 abroad for purchasing equity shares of a foreign listed company. Can he do so under the general resident-individual permission?

Answer: He may freely draw USD 250,000 under the resident-individual permission. For the excess USD 50,000, the specific regulation for investment in foreign securities (overseas investment rules) will apply, with its own limits/conditions.

### Example 2

Example 2: A US private equity fund wishes to invest in an Indian company that operates a chain of farm houses for rental. Is this permitted?

Answer: No. Construction of farm houses is a prohibited activity for non-resident investment under the FEM (PCAT) Regulations. (Note: The carve-out under 'real estate business' permits townships, residential/commercial premises, roads and bridges — but NOT farm houses.)

### Example 3

Example 3: An NRI wishes to subscribe to a chit fund in Kerala. Is this allowed?

Answer: Generally chit-fund investment by non-residents is prohibited. However, there is a carve-out: the Registrar of Chits (in consultation with the State Government) may permit chit funds to accept NRI subscriptions through banking channels and on non-repatriation basis, without limit, subject to RBI conditions.

### Example 4

Example 4: An Indian company has a representative office in Pyongyang, North Korea, set up in 2015. What action must be taken under the current FEMA framework?

Answer: Unless specifically approved by the Central Government, the representative office must be closed/liquidated/disposed/settled within 180 days of the relevant Notification, in line with the MEA Order S.O. 1549(E) dated 21 April 2017.

### Example 5

Example 5: Can RBI prevent a resident from remitting USD 50,000 to pay an installment on a foreign currency loan?

Answer: No. The proviso to Section 6(2) bars any restriction on drawal for amortisation of loans. Loan repayment is a non-restrictable drawal.

⚠️ Common exam mistakes

  • Forgetting that the USD 250,000 limit is financial year-based and is subsumed with LRS / Para 1 of Schedule III items.
  • Believing 'real estate business' bars all real estate investment by non-residents — actually, townships, residential/commercial premises, roads and bridges are permitted; only the business of real estate and farm houses are prohibited.
  • Missing the NRI carve-out for chit funds — students often state chit funds are absolutely prohibited.
  • Failing to mention the FATF non-cooperative countries restriction tied to the USD 250,000 cap.
  • Forgetting that for capital account transactions, the rule is reverse: permitted only if specifically allowed (unlike current account where everything is allowed unless prohibited).
  • Overlooking the DPRK (North Korea) prohibition and the 180-day liquidation requirement for existing assets/representative offices.
  • Confusing 'no restriction' under the proviso (amortisation, depreciation) with 'permissible' transactions — these are stronger: RBI cannot even impose restrictions on them.
Bare-Act text Section 6(2) Proviso and Regulation under FEM (Permissible Capital Account Transactions) Regulations, 2000 · Foreign Exchange Management Act, 1999; FEM (PCAT) Regulations, 2000; MEA Order S.O. 1549(E) dated 21 April 2017 · click to expand
Proviso to Section 6(2): Provided that the Reserve Bank or the Central Government shall not impose any restrictions on the drawal of foreign exchange for payment due on account of amortisation of loans or for depreciation of direct investments in the ordinary course of business. Regulation (Prohibited Transactions): (a) No person shall undertake or sell or draw foreign exchange to or from an authorised person for any capital account transaction, provided that a resident individual may draw from an authorised person foreign exchange not exceeding USD 250,000 per financial year or such amount as decided by Reserve Bank from time to time for a capital account transaction specified in Schedule I; ... no part of the foreign exchange of USD 250,000 drawn shall be used for remittance directly or indirectly to countries notified as non co-operative countries and territories by Financial Action Task Force (FATF). (b) A person resident outside India is prohibited from making investment in India in any company/firm/proprietary concern/entity engaged or proposing to engage in: chit fund (with NRI carve-out via Registrar of Chits on non-repatriation basis); Nidhi company; agricultural or plantation activities; real estate business or construction of farm houses (excluding development of townships, construction of residential/commercial premises, roads or bridges); trading in Transferable Development Rights (TDRs).
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