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FEMA & RBI

Your foreign holding company invests back into India. FEMA counts how many layers deep that structure goes

This isn't the ESOP-style foreign shareholding you may have already checked. It catches a founder's own personal stake in the HoldCo too, and it's triggered the moment that HoldCo's money comes back into India at all, into your company or any other.

Somewhere above your Indian operating company sits a foreign holding company, set up for a funding round, an eventual listing, or simply because investors wanted a Delaware or Singapore entity at the top of the structure. That HoldCo, or the founder personally through their stake in it, now wants to put money into another Indian business, a second venture, a JV, an acquisition. Nobody thinks of this as "overseas investment" needing FEMA clearance, because the money is coming back into India, not leaving it. RBI does think of it that way, and it specifically caps how many subsidiary layers a structure like this can run through once any part of it invests back into India.
Last reviewed: 6 September 20267 min readReviewed by Preetesh Maloo, CA

The short answer

Rule 19(3) of the FEMA (Overseas Investment) Rules, 2022 says no person resident in India, and that includes a resident individual founder personally, not only an Indian company, can hold a financial commitment in a foreign entity that has invested, or ever invests, into India, if doing so results in a structure with more than two layers of subsidiaries. The trigger is the round-trip itself, the foreign entity's money coming back into India, whether into your own operating company or an entirely different Indian business. This does not catch a simple minority, non-controlling stake with no control rights, an ESOP-type grant in a foreign parent, because that counts as Overseas Portfolio Investment, which this rule doesn't reach. It does catch a controlling or 10%-plus stake, whether held by the Indian company or by a founder personally, once the HoldCo's own structure runs more than two layers deep and any part of it touches India. Exactly how those layers get counted, from which entity the count starts, is genuinely debated among FEMA practitioners, which is why a specific structure needs a CA looking at the actual chart, not a general rule of thumb applied from a blog post.

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The question isn't tax, it's whether the structure is even allowed

A foreign HoldCo investing in a second Indian business feels like an ordinary group-expansion decision, and the instinct is to go straight to structuring it for tax efficiency. FEMA asks a prior question: does this structure, once the foreign entity's money comes back into India, run more layers deep than the rule permits. A HoldCo that never touches India at all doesn't trip this cap. The moment it invests into any Indian entity, including your own operating company for a second time, the round-trip trigger is live and the layer count matters.

This is a different rule from the one your ESOP already deals with

If Indian employees hold options in the same foreign parent, that's a separate, already-familiar obligation, reported through Form OPI, because a plain minority ESOP stake with no control counts as Overseas Portfolio Investment, not Overseas Direct Investment. Rule 19(3) works on the other side of that line. It reaches a stake that carries control or crosses 10%, held either by the Indian company itself or by a founder personally, since resident individuals can hold Overseas Direct Investment in their own name, not only through a corporate vehicle. A founder who personally owns a controlling slice of the HoldCo is inside this rule's reach directly, even if the Indian company's own shareholding in the HoldCo is smaller.

Counting the layers is where even FEMA practitioners disagree

A "subsidiary" here means an entity the foreign entity controls, which includes any 10%-plus stake. What's genuinely unsettled is the counting mechanics, whether the count starts at the Indian resident, at the first foreign entity, or somewhere else, and RBI hasn't spelled this out with the precision a founder would want before relying on it. Treat any confident-sounding rule of thumb, including one from a generic article, with caution. The safe approach is a CA mapping your actual structure against the rule, not assuming a specific tier is automatically clear.

A narrow group of entities this doesn't apply to

Banking companies, RBI-classified systemically important non-banking financial companies, insurance companies, and Government companies under the Companies Act, 2013 are exempted from the two-layer cap. Outside those regulated categories, which is nearly every founder-led company this applies to, the cap is live.

What goes wrong without a CA

The recurring pattern: the foreign HoldCo gets set up cleanly for the funding round it was built for, and nobody revisits the structure when it later wants to invest in a second Indian business, because that feels like a new, unrelated decision rather than a continuation of the same overseas-investment chain RBI is watching. It surfaces when that second investment needs its own FEMA reporting, or at a subsequent round's diligence, by which point the structure may already be a layer too deep, and reworking it after the fact is a far harder and costlier conversation than mapping it before the second investment was made.

What's involved

What the CA actually does

  1. 1

    We map your actual HoldCo structure against the round-trip trigger

    We look at what the foreign HoldCo owns, including any of its own subsidiaries, and confirm whether its structure, once it touches India, is within the two-layer limit.

  2. 2

    We work out whether each stake is OPI or ODI

    For the Indian company's own holding and for a founder's personal stake in the HoldCo, we confirm which side of the OPI/ODI line each sits on, since that decides whether Rule 19(3) reaches it at all.

  3. 3

    We flag a layering problem before your next investment, not after

    Before the HoldCo invests in a second Indian business, we check the structure against the cap, so a problem is caught while it's still simple to restructure around.

  4. 4

    We keep the position documented for investor and RBI scrutiny

    We record how the structure was assessed and why, so a later funding round, an investor's diligence, or an RBI query has a clear, defensible answer.

What to have ready

Documents you'll typically need

  • The group's full holding structure chart, including the foreign HoldCo and any of its own subsidiaries
  • The founder's personal shareholding or cap table in the foreign HoldCo, where held directly
  • The Indian company's shareholding in the foreign HoldCo, if any
  • Details of the second Indian entity or business the HoldCo intends to invest in
  • Any Form FC, Annual Performance Report, or Form OPI already filed for the same structure

References on this page

  • Rule 19(3), Foreign Exchange Management (Overseas Investment) Rules, 2022 (effective 22 August 2022): "No person resident in India shall make financial commitment in a foreign entity that has invested or invests into India, at the time of making such financial commitment or at any time thereafter, either directly or indirectly, resulting in a structure with more than two layers of subsidiaries"
  • "Financial commitment" under the Overseas Investment Rules excludes Overseas Portfolio Investment (OPI); a non-controlling, under-10% stake with no control rights, such as an ESOP-type grant in a foreign parent, is OPI and outside Rule 19(3)'s reach
  • Overseas Direct Investment (a 10%-plus stake, or any stake carrying control) is available to resident individuals directly, not only to Indian entities, under the Overseas Investment Rules framework
  • "Subsidiary" for this purpose carries the meaning given in the Overseas Investment Rules: an entity in which the foreign entity has control, which includes holding 10% or more of its equity
  • Rule 19(3) exempts banking companies, RBI-classified systemically important non-banking financial companies, insurance companies, and Government companies as defined under the Companies Act, 2013, from the two-layer cap

Frequently asked questions

Common questions

No, not yet. Rule 19(3) is triggered specifically by the round-trip, the foreign entity's money coming back into India. A HoldCo structure that stays entirely outside India doesn't hit this particular cap, though it may still have its own reporting obligations.

It can work against you, not for you. Resident individuals can hold Overseas Direct Investment directly, so a founder's personal controlling or 10%-plus stake in the HoldCo is assessed under this rule in its own right, separately from whatever the Indian company itself holds.

Generally no. A non-controlling stake under 10% with no control rights counts as Overseas Portfolio Investment, which sits outside Rule 19(3)'s reach. That's the situation the existing Form OPI reporting obligation already covers, a different filing for a different kind of stake.

Yes, banking companies, RBI-classified systemically important NBFCs, insurance companies, and Government companies under the Companies Act, 2013 are exempted. Almost every founder-led company outside those regulated sectors is not.

This is the part where even FEMA practitioners don't fully agree, RBI hasn't spelled out the precise counting mechanics. Rather than rely on a general rule of thumb, have a CA map your specific structure against the rule before you assume a given tier is clear.

Is your foreign HoldCo about to invest in a second Indian business?

Tell us how the structure is set up, and who holds what. A practising CA will map it against the two-layer cap before the investment is made, on a free call, no obligation.

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