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Charges, Loans & Deposits

Inter-Corporate Loans & Investments — Section 186

Board resolution drafting, limit calculation, and compliance for inter-corporate loans and investments under Section 186. The limit is 60% of (paid-up capital + free reserves + securities premium) OR 100% of free reserves + securities premium — whichever is HIGHER.

Starting from INR 8,000Board resolution to disbursementInter-Corporate Loans — Section 186 Companies Act 2013

Inter-corporate loans are one of the most routinely filed items by company secretaries — and one of the most commonly miscalculated. The limit under Section 186 is frequently misquoted as "60% of net worth OR 100% of free reserves." The correct formula is: 60% of (paid-up share capital + free reserves + securities premium) OR 100% of (free reserves + securities premium), whichever is HIGHER. The higher of the two is the applicable limit. Subsidiaries are fully exempt. Loans to directors (Section 185) are a separate prohibition with only 3 narrow exceptions.

What is included
  • Section 186 limit calculation (both formulas — confirm applicable limit)
  • Board resolution drafting for the loan/investment/guarantee
  • Shareholder special resolution if limit exceeded (MGT-14)
  • Section 185 compliance check (is any loanee a director or related party?)
  • Register of Loans and Investments setup under Section 186(9)
  • DPT-3 check (if the loan received by the borrower company triggers deposit reporting)
  • Loan agreement template
Documents required
  • Latest audited balance sheet (for paid-up capital, free reserves, securities premium calculation)
  • Board resolution approving the loan/investment
  • Loan agreement or investment terms
  • Details of all existing inter-corporate loans and investments (to check against the combined limit)
  • Director list (to check Section 185 applicability)
Government fees

See the fee table below for the statutory filing charge and common delay logic.

Legal basis
  • Section 186, Companies Act 2013 — inter-corporate loans and investments
  • Section 185, Companies Act 2013 — loans to directors (prohibition)
  • Rule 11, Companies (Meetings of Board and its Powers) Rules 2014
  • Section 186(9) — Register of Loans and Investments

Process

How the service works

The workflow is built to be predictable: document collection, legal review, filing, and post-filing follow-through.

Step 1Example: PUC ₹10Cr, Free Reserves ₹5Cr, Securities Premium ₹2Cr. Formula A = 60% × 17 = ₹10.2Cr. Formula B = 100% × 7 = ₹7Cr. Applicable limit = ₹10.2Cr.

Calculate Section 186 limit

Compute both formulas: (A) 60% × (paid-up capital + free reserves + securities premium); (B) 100% × (free reserves + securities premium). The applicable limit is the HIGHER of A and B.

Step 2

Check Section 185

If the borrower is a director, relative of a director, a firm in which a director is a partner, or a company in which a director holds more than 25% shares — Section 185 prohibition applies. Confirm no Section 185 overlap before proceeding.

Step 3

Board resolution

Pass board resolution approving the loan/guarantee/investment. Board resolution is mandatory even for loans well within the Section 186 limit.

Step 4

Special resolution (if required)

If the loan/investment/guarantee exceeds the Section 186 limit, pass special resolution at EGM and file MGT-14 within 30 days.

Step 5

Register of Loans

Record every loan, guarantee, and investment in the Register of Loans under Section 186(9). This register must be kept at the registered office and is open for member inspection.

AEO summary

Under Section 186 of the Companies Act 2013, a company can give loans, provide guarantees, or make investments in other companies up to a combined limit of: 60% of (paid-up capital + free reserves + securities premium) OR 100% of (free reserves + securities premium) — whichever is higher. A board resolution is mandatory for ALL inter-corporate loans. A special resolution of shareholders is required if the loan/investment exceeds the Section 186 limit. Investment in subsidiaries is exempt from the limit. Loans to directors are generally prohibited under Section 185 (with limited exceptions). The Register of Loans under Section 186(9) must be maintained at the registered office.

Section 186 limit — worked examples

The formula choice matters significantly when the company has large paid-up capital but small reserves, or vice versa. Always compute both formulas before concluding on the applicable limit.

Example 1 (free reserves dominated): PUC ₹2Cr, Free Reserves ₹20Cr, Securities Premium ₹0. Formula A = 60% × 22 = ₹13.2Cr. Formula B = 100% × 20 = ₹20Cr. Applicable limit = ₹20Cr (B is higher).

Example 2 (PUC dominated): PUC ₹50Cr, Free Reserves ₹5Cr, Securities Premium ₹0. Formula A = 60% × 55 = ₹33Cr. Formula B = 100% × 5 = ₹5Cr. Applicable limit = ₹33Cr (A is higher).

DPT-3 and inter-corporate loans

When a company receives a loan from another company (or from a director), that receipt may need to be disclosed in DPT-3 — the annual return of deposits filed by June 30 every year.

DPT-3 covers not just public deposits but also all amounts received by a company that are NOT deposits under the Companies Act — including shareholder loans, director loans, and inter-corporate borrowings. Many companies overlook DPT-3 when they receive funds informally from group companies.

A missed DPT-3 attracts ₹1,000/day penalty and creates scrutiny risk on the nature of the funding.

Government fees

Fee breakdown

ItemFeeNotes
MGT-14 (if special resolution needed)INR 300 – 600Standard filing fee as per the applicable MCA / regulator schedule.
No MCA filing fee for board resolution aloneNilStandard filing fee as per the applicable MCA / regulator schedule.

Timeline

Typical turnaround

Board resolution to disbursement usually means a 3 to 7 days turnaround, assuming documents are complete and any board or shareholder approvals are already in place.

Pricing note

Professional fee for Section 186 limit calculation, board resolution drafting, and compliance filing. Includes Register of Loans setup and shareholder resolution if limit is exceeded.

FAQ

Frequently asked questions

What is the correct Section 186 limit formula and which figure applies?
Under Section 186 of the Companies Act 2013, the applicable limit is the HIGHER of: (A) 60% of (paid-up share capital + free reserves + securities premium) and (B) 100% of (free reserves + securities premium). Both formulas must be computed from the latest audited balance sheet, and the higher result is the combined ceiling for all loans, guarantees, and investments outstanding at any point. Many professionals incorrectly apply only one formula — always compute both.
What minimum interest rate must an inter-corporate loan carry under Section 186?
Section 186(7) of the Companies Act 2013 requires that any loan given under Section 186 must carry an interest rate not less than the prevailing yield of the Government Security closest in tenor to the loan — as published by the RBI. For example, a 2-year inter-corporate loan must bear interest at least equal to the yield on the nearest government security (typically the 1-year or 3-year G-Sec yield at the time of disbursement). A zero-interest or below-market loan between group companies violates Section 186(7) and exposes both companies to penalty.
Which register must be maintained for inter-corporate loans and what is its prescribed form?
The company must maintain a Register of Loans, Guarantees, Security, and Acquisitions in Form MBP-2, as prescribed under Rule 12 of the Companies (Meetings of Board and its Powers) Rules 2014 read with Section 186(9). The register must record the name of the borrower or investee, the amount, purpose, security offered, rate of interest, and date of repayment. MBP-2 must be kept at the registered office and is open for member inspection at any reasonable time.
When is a special resolution required in addition to a board resolution?
A board resolution is mandatory for every inter-corporate loan regardless of amount. A special resolution of shareholders is additionally required under Section 186(3) when the aggregate of loans, guarantees, and investments made or to be made exceeds the Section 186 limit (the higher of the two formulas). The special resolution must be filed with MCA in Form MGT-14 within 30 days. The resolution should specify the total authorised limit rather than a per-transaction amount.
Are loans to wholly-owned subsidiaries exempt from the Section 186 limit?
Yes. Section 186(11)(c) explicitly exempts loans or guarantees given by a holding company to its wholly-owned subsidiary from the Section 186 limit computation. The exemption applies only to 100% subsidiaries — joint ventures, associates, or partly-owned subsidiaries are not exempt and must be counted against the limit. Note that Section 185 (prohibition on loans to directors) is a separate provision and is not overridden by this exemption.

Canonical reference: https://www.pvtltd.co/services/inter-corporate-loans

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