CS Pooja (Company Secretary) 13 August 2009

APR to include step down subsidiaries??

An Indian Company has a WOS in Mauritius, to whom RBI has allotted the UIN too. The Mauritian company has further invested in one JV and Subsidiary in Sharjah (under SAIF Zone).

Now, the questions are:

1. Is APR to be filed by Indian Company to include only Mauritian Company details, (as UIN is allotted to it) and the details of step down subsidiaries in Sharjah Co.s are not be stated in it??

2. If the answer is yes, then as per Regulation 13 of Foreign Exchange Management (amendment) Regulations, 2004, aint the matters like setting up of Step down subsidiary to be included in APR and forwarded to RBI.

3. If the answer to above is again yes, then how the same should be incorporated in APR.

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4 Replies

A V Vishal (Advocate) 14 August 2009

In my opinion the details of the sharjah company need not be disclosed.

CS Pooja (Company Secretary) 17 August 2009

But Regulation 13 says so....

CS Pooja (Company Secretary) 22 August 2009

In connection with the above issue itself, the new format of APR (Under ODI) has been introduced.

Does anybody possess the information (any circular or other note) as to whether the old one is redundant now??

CS Pooja (Company Secretary) 11 September 2009

Dear All

I shall be replying my own query regarding APR:

1. Yes. Old form of APR is redundant.

2. The formation of step subsidiary in Sharjah will be given under Clause VI of the new form.

3. If any further details need to be provided (for the sake of avoiding further questioning back from RBI), the same can be done by way of a foot note.

Since, I waited for members’ response for almost a month but didn’t get any, I went to RBI. The above clarifications were provided by their Forex Deptt.

Hope the above will be useful to all..