New form MGT-6 w.e.f. July 15, 2024

Only a natural person can be a beneficial owner while reporting e-form MGT-6? It seems so from MCA recent notification on this.

MCA has introduced new MGT-6 e-form ("MGT-6") on 15th July 2024 which is web-based form.

The purpose of MGT-6 is to report details of persons who is registered owner and beneficial owner respectively by a company. There are scenarios where there is a need to file this MGT-6. One of such scenarios is when a company incorporates wholly owned subsidiary (Say, private limited company). This means total shares held by holding company. But, you may know that minimum two members are required in a private limited company. So in such case, holding company nominates a person (say, its employee) to hold share for such statutory requirement whereas beneficial interest in such share is held by holding company only. So, this is a brief background of MGT-6.

There are two attachments to this MGT-6 which are submitted to a company:

• MGT-4: This is submitted by registered owner.
• MGT-5: This is submitted by beneficial owner.

The way new MGT-6 is structured , it seems that only natural person details can be submitted in MGT-6. Just look at details of beneficial owner asked in MGT-6:

First, PAN and passport details being asked whereas in earlier form there were no such requirement.

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Second, only natural person has date of birth and nationality, body corporate has date of incorporation.

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Third, only natural person has father/spouse name, not body corporate:

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Having observed such details, I feel that MCA intention is to have details of natural person. 

Do you also feel the same that only natural person details can be filed in MGT-6?