site logo

ndsadvisors.com

FC-TRS · FEMA · FIRMS · Share Transfer

FC-TRS Filing Services share transfers reported within 60 days.

End-to-end FC-TRS filing services on the FIRMS portal of the Reserve Bank of India — reporting of transfer of shares of an Indian company between a resident and a non-resident under FEMA, valuation, AD bank coordination, and Late Submission Fee management.

Form FC-TRS is the FEMA reporting form used to report any transfer of shares or convertible debentures of an Indian company between a person resident in India and a person resident outside India. The form is filed on the FIRMS portal of the Reserve Bank of India under the Single Master Form framework. Every time foreign capital moves into or out of an Indian company's cap table — whether on a sale, gift, or transfer by operation of law — an FC-TRS filing is triggered, even where no fresh issuance of shares is involved.

The reporting timeline is strict — 60 days from the date of receipt of consideration or the date of transfer of shares, whichever is earlier. The transfer must comply with FEMA pricing guidelines, which require a fair value valuation report from a Chartered Accountant or merchant banker. Common scenarios include exits by foreign investors, secondary sales between non-residents, sale of shares by Indian promoters to foreign acquirers, gifts of shares by non-resident parents to resident children, and inter-se transfers among NRI family members. Each is treated as a separate FC-TRS event regardless of value.

Our FC-TRS practice handles share transfer reporting for startups, mid-market companies, listed entities, and private equity-backed businesses. We review the transfer documents, undertake FEMA pricing diligence, coordinate the valuation report, prepare the FC-TRS form with all attachments, file on the FIRMS portal within the 60-day window, and respond to AD bank queries. Where past transfers have been missed, we manage Late Submission Fee payments and compounding applications before the Reserve Bank of India.

Our FC-TRS Services

01

Transfer Structure Review

FEMA classification of the transfer — sale, gift, inter-se, or transfer by operation of law.

02

Pricing Diligence

FEMA pricing diligence and floor/cap analysis as per the Non-Debt Instruments Rules.

03

Valuation Report

FEMA-compliant valuation by Chartered Accountant or merchant banker for transfer price.

04

FC-TRS Drafting

Drafting of Form FC-TRS with consent letters, KYC, FIRC, and supporting documents.

05

FIRMS Filing

Filing of FC-TRS on the FIRMS portal under SMF within 60 days of consideration.

06

AD Bank Coordination

End-to-end coordination with the authorised dealer bank for KYC, FIRC, and approvals.

07

LSF & Compounding

Late Submission Fee filings and compounding applications before RBI for delayed filings.

08

Gift & Inter-Se Transfers

FC-TRS reporting for gifts, inter-se NRI transfers, and transfers by operation of law.

Our FC-TRS Workflow

1

Transfer Review

Review of share transfer documents, parties, and FEMA classification.

2

Valuation

Valuation of shares under FEMA pricing rules to determine the floor or ceiling price.

3

Documentation

Drafting of CA, CS, and statutory certificates, consent letters, and KYC.

4

SMF Filing

Filing of FC-TRS within 60 days on the FIRMS portal with all attachments.

5

AD Bank Approval

Response to AD bank queries and archival of approved acknowledgement.

Benefits of Timely FC-TRS Filing

Full FEMA compliance on share transfers
Avoidance of Late Submission Fee
Protection from compounding action
Clean cap table on FIRMS portal
Smooth repatriation of exit proceeds
Defensible transfer price under audit
Diligence-ready FEMA position
Banking comfort with AD bank

Frequently Asked Questions

Form FC-TRS is the FEMA reporting form filed for transfer of shares of an Indian company between a person resident in India and a person resident outside India.

Form FC-TRS must be filed within 60 days from the date of receipt of consideration for transfer of shares or transfer of shares, whichever is earlier.

The onus of filing FC-TRS is on the resident transferor or resident transferee to the transaction, or on the investee Indian company in certain cases.

Yes. A valuation report from a Chartered Accountant or merchant banker is required to support the transfer price under FEMA pricing guidelines.

Late filing attracts Late Submission Fee under FEMA and may trigger compounding proceedings before the Reserve Bank of India.

Share Transfer Just Completed?

Whether you are reporting an exit, secondary sale, gift, or inter-se transfer of shares involving a non-resident, talk to our team for accurate FC-TRS filing within the 60-day window.

File FC-TRS or call +91 9819 000 511