Corporate GovernanceIndia
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Corporate Governance

India corporate governance for foreign subsidiaries

Board composition and governance, independent director appointment, related party transaction approval, audit committee, nomination committee and corporate governance compliance for foreign owned Indian subsidiaries.

Counsel that connects the technical, the commercial, and the legal, across ten offices in India.
Companies Act
Governance
SEBI LODR
Listed Entities
Board
Compliance
10
India Offices
01

Board composition and director obligations

  • At least one director must be resident in India (182 days stay in previous calendar year).
  • Maximum 15 directors (more with special resolution); woman director mandatory for certain classes.
  • Director duties under Sections 166 and 167: fiduciary duty, no conflict of interest, independent judgment.
  • Foreign nominee directors: liability exposure, DIN requirement and DIR 3 KYC annual compliance.
02

Related party transaction governance

  • Related party transactions under Section 188: board and shareholder approval requirements.
  • Arms length pricing requirement and justification documentation.
  • Interested director cannot vote on RPT resolutions at board level.
  • Transfer pricing intersection: Section 188 compliance concurrent with FEMA and income tax TP requirements.
03

Mandatory committees and compliance

  • Audit committee: mandatory for prescribed classes of companies (all listed, capital above INR 10 crore, turnover above INR 100 crore, borrowings above INR 50 crore).
  • Nomination and Remuneration Committee: for prescribed classes.
  • Corporate Social Responsibility (CSR) Committee: for companies with net worth above INR 500 crore, turnover above INR 1,000 crore or profit above INR 5 crore.
  • Vigil mechanism and internal financial controls certification.
04

How AMLEGALS assists

  • Board governance structuring for foreign owned subsidiaries.
  • Independent director identification and appointment advisory.
  • Related party transaction policy design and compliance monitoring.
  • Audit committee charter, CSR compliance and annual governance review.
Answers

What clients ask before they commit.

Short, direct, on the record.

01Must a foreign owned Indian subsidiary have an independent director?

An independent director is mandatory for listed companies and for prescribed classes including public companies with paid up capital of INR 10 crore or more, turnover of INR 100 crore or more, or aggregate outstanding loans of INR 50 crore or more. Private limited companies (most foreign subsidiaries) are generally exempt unless they meet these thresholds.

02What related party transaction approvals are required?

RPTs must be approved by the board (with interested directors abstaining) and by shareholders through ordinary resolution if the transaction exceeds prescribed thresholds. For listed companies, SEBI LODR requires prior approval of the audit committee and shareholders through ordinary resolution for material RPTs. All RPTs must be disclosed in the board report.

03Can all directors of an Indian subsidiary be foreign nationals?

No. At least one director must be a person who has stayed in India for a total period of not less than 182 days during the previous calendar year (resident director under Section 149(3)). The remaining directors can be foreign nationals with valid DINs and annual DIR 3 KYC compliance.

04Is CSR mandatory for foreign owned subsidiaries?

CSR is mandatory if the Indian subsidiary has net worth of INR 500 crore or more, turnover of INR 1,000 crore or more, or net profit of INR 5 crore or more during the immediately preceding financial year. The company must spend 2% of average net profit of the preceding 3 years on eligible CSR activities.

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