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Microlesson · 5-min read

Schedule III — Persons Other Than Individuals

# Schedule III — Persons Other Than Individuals

When the remitter is a company, firm, LLP or other non-individual PRI, Schedule III prescribes specific ceilings for each head of remittance. Within the ceiling → no RBI approval; above the ceiling → RBI approval is required.

## 1. Consultancy charges from abroad

Sector of projectLimit (no approval up to)
Infrastructure projectsUp to US $1 Crore (US $10 million) per project
Other projectsUp to US $10 Lakh (US $1 million) per project

Above these limits → RBI approval.

## 2. Donations by a Corporate

Permitted donations cover:

  • A Chair in an educational institute
  • An educational institute
  • Activities related to the donor's business
  • NOT to investment funds

### Limit (no approval — LOWER of):

  • 1% of foreign exchange earnings during preceding 3 FYs (average), OR
  • US $5,00,000 (US $5 lakh)

Exceeding → RBI approval.

## 3. Commission on Sale of Plots in India

When an Indian seller pays commission to a foreign agent for sale of plots in India:

### Limit (no approval — LOWER of):

  • 5% of inward remittance, OR
  • US $25,000

Exceeding → RBI approval.

## 4. Pre-Incorporation Expenses

Reimbursement of pre-incorporation expenses incurred abroad by a foreign promoter:

### Limit (no approval — HIGHER of):

  • 5% of inward remittance, OR
  • US $1,00,000 (US $100,000)

Above → RBI approval.

## Quick reference table

Remittance headCeiling (no approval)Above ceiling
Consultancy — InfrastructureUS $1 croreRBI approval
Consultancy — OthersUS $10 lakhRBI approval
Corporate donationLOWER of 1% of avg 3-yr forex earnings or US $5 lakhRBI approval
Commission on plot saleLOWER of 5% of inward remittance or US $25,000RBI approval
Pre-incorporation expense reimbursementHIGHER of 5% of inward remittance or US $1 lakhRBI approval

## Tip on "higher of" vs "lower of"

Asymmetry: corporate donation and plot-sale commission use the LOWER of two limits (restrictive); pre-incorporation expense uses the HIGHER of the two (liberal — to support new business). Memorise this difference.

Worked example

### Example 1

Example 1 — Consultancy for highway project

ABC Infra Ltd hires a German consultant for US $80 lakh for a national highway.

Answer: Highway = infrastructure → limit US $1 crore. US $80 lakh < US $1 crore → no RBI approval.

### Example 2

Example 2 — Donation by manufacturing company

XYZ Ltd's average 3-yr forex earnings = US $20 million. 1% = US $2 lakh. It wishes to donate US $4 lakh to a US university for a chair.

Answer: Limit = LOWER of US $2 lakh and US $5 lakh = US $2 lakh. Proposed US $4 lakh > limit → RBI approval required.

### Example 3

Example 3 — Commission on plot sale

A developer receives US $10 lakh inward remittance for a Mumbai plot and pays 4% commission (US $40,000) to a foreign agent.

Answer: Limit = LOWER of 5% (US $50,000) and US $25,000 = US $25,000. US $40,000 > US $25,000 → RBI approval required.

### Example 4

Example 4 — Pre-incorporation expense reimbursement

US promoter incurred US $1.5 lakh pre-incorporation expenses; Indian subsidiary received US $20 lakh inward capital.

Answer: Limit = HIGHER of 5% of US $20 lakh (= US $1 lakh) and US $1 lakh = US $1 lakh. US $1.5 lakh > US $1 lakh → RBI approval required.

⚠️ Common exam mistakes

  • Reversing 'lower of' and 'higher of' between donations, plot-sale commission, and pre-incorporation expenses.
  • Treating the consultancy infrastructure limit (US $1 crore) as applicable to all consultancies — non-infrastructure has only US $10 lakh.
  • Using current year forex earnings instead of average of preceding 3 years for the donation 1% computation.
  • Forgetting corporate donations cannot be to investment funds — only educational/business-related causes.
Bare-Act text Schedule III (Rule 5) · Foreign Exchange Management (Current Account Transactions) Rules, 2000 · click to expand
Drawal of foreign exchange by an entity in India for the following purposes is permitted up to specified limits, beyond which prior approval of the Reserve Bank is required: (i) Donations exceeding 1% of the foreign exchange earnings during the previous three financial years or US $5,000,000, whichever is less, by a corporate, for creation of Chairs in reputed educational institutes, to funds promoted by educational institutes, to a technical institution or body or association in the field of activity of the donor company; (ii) Commission to agents abroad for sale of residential flats or commercial plots in India exceeding US $25,000 or 5% of the inward remittance, whichever is less; (iii) Remittances exceeding US $10,000,000 per project for any consultancy services in respect of infrastructure projects and US $1,000,000 per project for other consultancy services procured from outside India; (iv) Remittances exceeding 5% of investment brought into India or US $100,000 whichever is higher, by an entity in India by way of reimbursement of pre-incorporation expenses.
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