Wednesday, 3 February 2016

Appointment of Foreign Citizen as Whole Time Director

Appointment Of Foreign Citizen as Managing Director, Whole-time Director Or Manager
 Section 196 of Companies Act, 2016
·        No Company shall appoint or employ at the same time a managing director, whole-time director and a manager.
·        No Company shall appoint or re-appoint any person as its managing director , whole-time director or manager for a term exceeding five years at a time:
Provided that no re-appointment shall be made earlier than one year before the expiry of                                                          his term
·         No company shall appoint or continue the employment of any person as managing                                            director, whole-time director or manager who-
(a) is below the of 21 years or has attained the age of70 years:
     Provided that appointment of a person who has attained the age of seventy years may be made by passing a special resolution in which case the explanatory statement annexed to the notice of such motion shall indicate the justification of appointing such person;
(b) is an undischarged insolvent or has at any time been adjudged as an insolvent;
(c) has at any time suspended payment to his creditors or makers, or has at any time made, a composition with them; or
(d) has at any time being convicted by court of an offence and sentenced for a period of more than six months.
·         Subject to the provision of section 197 and schedule V,  a managing director, whole-time director or manager shall be appointed and the terms and condition of such appointment and remuneration payable be approved by the board of directors at a meeting which shall be subject to approval by a resolution at the next general meeting of the company and by the central government in case of such appointment is at variance to the conditions specified in that schedule:
Provided that notice convening board or general meeting for considering such appointment shall include the terms and condition of such appointment , remuneration payable and such other matters including interest ,of a director or directors in such appointments , if any:
Provided further that a return in the prescribed form shall be filled within sixty days of such appointment with the registrar.
·         Subject to the provision of this act, where an appointment of a managing director, whole-time director or manager is not approved by the company at a general meeting , any act done by him before such approval shall not be deemed to be invalid.
Rule 3 of Companies ( Appointment & Remuneration of Managerial Personnel) Rules , 2014
A company shall file a return of appointment of a managing director , whole time director or manager, chief Executive Officer (CEO), Company Secretary and Chief Financial Officer (CFO), within 60 days of the appointment, with the registrar in Form No. MR.1 along with such fee as prescribed under Companies (Registration Offices and Fees) Rules, 2014.
Part 1 of the Schedule V to the Companies Act,2013
Apart from this, Part 1 of the Schedule V contains certain conditions, which must be satisfied by a person to be eligible for appointment as managing director/whole-time director/manager without the approval of Central Government. Part 1 of the Schedule V reads:
No person shall be eligible for appointment as a managing director or a whole-time director or a manager (hereinafter referred to as managerial person) of a company, unless he satisfies a following conditions, namely:
·         He had not been sentenced to imprisonment for any period, or to a fine exceeding Rs. 1,000, for the conviction of an offence under any of the following 16 acts, namely Indian Stamp Act; Central Excise Act; IDRA; Prevention of Food Alteration Act; Essential Commodities Act; Companies Act; SCRA; Wealth Tax Act; Income Tax Act; Customs Act; Competition Act; FEMA; SICA; SEBI Act; FT(D & R) Act; and Prevention of Money Laundering Act, 2002 :
Provided that where the Central Government has given its approval to the appointment of a person convicted, no further approval of that person , if he had not been convicted subsequent to such approval; 
·         He had not been detained for any period under the conservation of Foreign Exchange and Prevention of Smuggling Activities, 1974:
Provided that where the Central Government has given its approval to the appointment of a person detained, no further approval of the Central Government shall be necessary for the subsequent appointment of that person, if he had not been so detained subsequent to such approval;
·         He has completed the age of 21 years but has not attained the age of 70 years. 
However , a person who has attained the age of 70 years can be appointed as the managerial person without the approval of the Central Government; provided his appointment is approved by a special resolution passed by the company in general meeting;
·         Where he is a managerial person in more than one company, he draws remuneration from one or both companies, provided that the total remuneration drawn from the companies does not exceed the higher maximum limit admissible from any of the companies of which he is a managerial person;
·         He is resident in India. Here, resident in India includes a person who has been staying in India for a continuous period of not less than 12 months immediately preceding the date of his appointment as a managerial person and who has come to stay in India------
(i)  for taking up employment in India; or
(ii) for carrying on a business or vocation in India.
It may be noted that this condition shall not apply to that companies in Special Economic Zones.
What are the compliances if in case a Foreign citizen is being appointed as Whole Time Director?
Central Government approval is required.
eForm MR 2 is required to be filed. eForm MR 2 is Form of application to the Central Government for approval of appointment or reappointment and remuneration or increase in remuneration or waiver for excess or over payment to managing director or whole time director or manager and commission or remuneration to directors
Take note that application seeking approval shall be made to CG within a period of Ninety days from the date of such appointment.
It is mandatory that the foreign Citizen is having valid DIN. The Foreign Citizen must have valid Passport as Identity Proof.
Meetings to be held in this compliance;
-          Board Meeting
-          Remuneration & Nomination Committee Meeting
-          Shareholders Meeting
Apart from eForm MR 2, eForm MGT 14 is also required to be filed to file the Special Resolution.
Attachments to eForm MR 2 in case you are appointing Whole Time Director as a Foreign Citizen;
-          Certified true copy of the resolution of Board of directors
-          Copy of the resolution of nomination and remuneration committee
-          Certified true copy of resolution of shareholder(s) along with notice
-          Certificate from the auditor or company secretary
-          Newspaper clipping in which notices are issued
-          Copy of employment visa/ passport, in case the proposed appointee is a foreign citizen.
-          Copies of educational or professional qualification certificate
-          Projections of the Turnover and net profits for next three years
-          Full and proper justification in favor of the proposal

Govt fees for filing eForm MR 2 would range from Rs. 2000 to Rs. 20,000 depending upon the Authorised Share capital of the company       

For more details, contact CS Neha Seth at 9871903449 or csnehaseth@gmail.com 

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