By Vivek Mimani, Mohit Maheshwari, Khusboo Agarwal
The Reserve Bank of India (RBI) vide circular dated 16 November 2015 had permitted foreign direct investment (FDI) in investment vehicles, i.e., any entity registered and regulated by Securities and Exchange Board of India (SEBI), including alternative investment funds (AIFs), real estate investment trusts (REITs) and infrastructure investment trusts (InvITs) (together Investment Vehicles), (2015 Notification) without prescribing any detailed reporting format. RBI vide its circular dated 7 June 2018 (Reporting Notification), has now prescribed reporting norms for FDI in Investment Vehicles.
The Reporting Notification introduces a Single Master Form (SMF), which will integrate the reporting structures for the various forms of foreign investment in Indian entities, including Investment Vehicles in India. The SMF requires reporting of foreign investments in Indian entities, including the downstream investments, as well as reporting of investments received from persons resident outside India in AIFs and other Investment Vehicles. The SMF has to be filed online by the Indian resident. The SMF is yet to be implemented.