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Microlesson · 5-min read

Declaration of Dividend in Case of Inadequacy or Absence of Profits (Rule 3)

# Declaration of Dividend out of Free Reserves — Rule 3 of Companies (Declaration and Payment of Dividend) Rules, 2014

Where a company has inadequate or no profits in the current year but still wishes to declare a dividend, it may draw on the accumulated profits transferred to free reserves, subject to four cumulative conditions.

## The Four Conditions — All Must Be Satisfied

### Condition I — Cap on Rate

The rate of dividend shall not exceed the average rate at which dividend was declared in the immediately preceding 3 financial years.

$$\text{Rate of Dividend} \leq \frac{RD_1 + RD_2 + RD_3}{3}$$

Exception: If no dividend was declared in any of the preceding 3 years, this cap does NOT apply.

### Condition II — Cap on Quantum

The total amount drawn from accumulated profits shall not exceed 10% of (Paid-up Share Capital + Free Reserves) as per the latest audited financial statement.

### Condition III — Set Off Current Year's Losses First

The amount drawn shall first be utilised to set off the losses incurred in the financial year in which dividend is declared. Only the balance can fund the dividend.

### Condition IV — Minimum Residual Reserves

After withdrawal, the balance of free reserves shall not fall below 15% of paid-up share capital (as per latest audited financial statement).

## Exemption — 100% Government Companies

These four conditions do NOT apply to government companies in which the entire paid-up share capital is held by:

  • The Central Government, or
  • One or more State Governments, or
  • Both the CG and any SG(s).

## Logic

Rule 3 exists to balance two competing interests:

  • Shareholders' expectation of dividend continuity even in a lean year,
  • Creditor protection by preventing reserves from being drained.

The four conditions act like guardrails: rate cap, quantum cap, current-year loss absorption, and a permanent reserves floor.

## Key Takeaway

Remember the 3-10-15 rule of thumb: 3-year average rate cap, 10% of (PUSC + Free Reserves) maximum withdrawal, 15% of PUSC minimum reserves remaining.

Worked example

### Example 1

Example (All four checks): XYZ Ltd. has:

  • Paid-up Share Capital = ₹100 crore
  • Free Reserves = ₹80 crore
  • Dividend rates in last 3 FYs: 12%, 18%, 15%
  • Current FY loss = ₹2 crore

Step 1 (Condition I): Max rate = (12 + 18 + 15)/3 = 15%. Max amount on 100 crore PUSC = ₹15 crore.

Step 2 (Condition II): Max amount = 10% × (100 + 80) = ₹18 crore.

Step 3 (Condition III): Adjust ₹2 crore current loss first. So dividend = Drawn amount − ₹2 crore.

Step 4 (Condition IV): After withdrawal, free reserves must be ≥ 15% × 100 = ₹15 crore. So max withdrawal = 80 − 15 = ₹65 crore.

Overall ceiling = lowest of (15, 18, 65) = ₹15 crore. After setting off ₹2 crore loss, dividend = ₹13 crore.

### Example 2

Example (Exception to Condition I): ABC Ltd. did not declare any dividend in the last 3 financial years. In FY 2024-25, it has inadequate profits. Condition I (3-year average rate cap) does NOT apply. Conditions II, III and IV must still be satisfied.

⚠️ Common exam mistakes

  • Forgetting that all four conditions must be satisfied cumulatively.
  • Computing Condition II base as PUSC only — it is PUSC plus free reserves.
  • Computing Condition IV base on (PUSC + Free Reserves) — it is only on PUSC.
  • Ignoring Condition III — current-year loss must be absorbed first from the withdrawn amount.
  • Forgetting the exception for wholly government-owned companies, where none of the conditions apply.
Bare-Act text Rule 3 · Companies (Declaration and Payment of Dividend) Rules, 2014 · click to expand
Rule 3, Companies (Declaration and Payment of Dividend) Rules, 2014: In the event of inadequacy or absence of profits in any year, a company may declare dividend out of free reserves subject to the fulfillment of the following conditions, namely: (1) The rate of dividend declared shall not exceed the average of the rates at which dividend was declared by it in the three years immediately preceding that year: Provided that this sub-rule shall not apply to a company, which has not declared any dividend in each of the three preceding financial year. (2) The total amount to be drawn from such accumulated profits shall not exceed one-tenth of the sum of its paid-up share capital and free reserves as appearing in the latest audited financial statement. (3) The amount so drawn shall first be utilised to set off the losses incurred in the financial year in which dividend is declared before any dividend in respect of equity shares is declared. (4) The balance of reserves after such withdrawal shall not fall below fifteen per cent of its paid up share capital as appearing in the latest audited financial statement.
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