FC-TRS Filing Services
Shares changing hands across the resident line trigger their own reporting — and a price that has to sit on the right side of fair value.
Form FC-TRS reports the transfer of capital instruments of an Indian company between a person resident in India and a person resident outside India, and is filed on the RBI's FIRMS portal within 60 days of the transfer or of the receipt or remittance of funds, whichever is earlier. The price must comply with the FEMA pricing guidelines supported by a valuation certificate, and the filing is made through the Indian company or the resident party depending on the nature of the transfer.
What our FC-TRS service covers
Eligibility, pricing, documents and filing.
- Confirming the transfer is permitted under the sectoral route and caps
- Applying the pricing guidelines to the direction of the transfer
- Valuation certificate from a chartered accountant or merchant banker
- Share transfer deeds, consent letters and AD bank documentation
- Filing FC-TRS on the FIRMS portal within 60 days
- Late Submission Fee computation where the filing is delayed
The four inputs to an FC-TRS
The form is quick; the supporting file is not.
Direction of transfer
Resident to non-resident, or non-resident to resident, which determines whether fair value acts as a floor or a ceiling.
Valuation
A certificate supporting the transfer price, prepared under an internationally accepted pricing methodology.
Transfer documents
Share transfer forms, consent letters from transferor and transferee, and board approval for the transfer.
AD bank documents
The FIRC or outward remittance evidence and the KYC report of the non-resident party.
Our process
From transfer agreement to acknowledged filing.
Eligibility check
Confirming the sector permits the transfer and identifying any approval requirement.
Valuation and pricing
Establishing fair value and confirming the agreed price complies with the guidelines.
Documentation
Transfer deeds, consents, declarations and AD bank certificates assembled.
Filing
FC-TRS filed on FIRMS within 60 days and tracked through to acknowledgement.
Where FC-TRS filings fail
What sets our approach apart.
The clock starts at the earlier date
Sixty days runs from the transfer or the movement of funds, whichever comes first — not from when the share transfer is recorded in the register of members.
Pricing works in one direction
A non-resident buying from a resident cannot pay below fair value, and a resident buying from a non-resident cannot pay above it.
Gift transfers have their own route
A transfer by way of gift between a resident and a non-resident may require prior approval, and is not simply a zero-consideration FC-TRS.
FC-TRS Filing Services questions answered
What people ask before engaging us.
Transferring shares to or from a non-resident?
We will check the pricing and the route before the transfer is executed.
