FC-TRS Filing — Transfer Reported. FEMA Compliant.
Every transfer of shares between a resident and a non-resident must be reported to the RBI through Form FC-TRS within 60 days — we prepare the form, verify valuation compliance, and file on the FIRMS portal.
Contact UsForm FC-TRS (Foreign Currency Transfer of Shares) is the prescribed RBI form for reporting transfer of equity shares, compulsorily convertible preference shares, or compulsorily convertible debentures of an Indian company between a person resident in India and a person resident outside India. The form must be filed within 60 days of receipt or remittance of the transfer consideration — whichever occurs first. Filing responsibility rests on the resident party: the resident transferor (seller) or resident transferee (buyer).
FC-TRS has two critical compliance dimensions that go beyond mere form-filling. First, pricing compliance: for unlisted companies, the transfer price must conform to the Fair Market Value determined by the Discounted Cash Flow (DCF) methodology by a SEBI-registered Chartered Accountant. For listed companies, the price must be within the SEBI-prescribed market range. A transfer at a price that violates these norms is a FEMA violation regardless of whether FC-TRS is filed.
Second, the filing is routed through the company's Authorised Dealer (AD) bank, which performs a first-level KYC and FEMA compliance check before uploading the form on the FIRMS portal. Getting the AD bank's sign-off requires a complete, well-prepared package. We manage the complete FC-TRS process — from transaction review and valuation check to AD bank coordination and FIRMS portal filing.
Our FC-TRS Filing Services Services
FC-TRS Form Preparation
Preparation of Form FC-TRS with all details of the share transfer — parties, instrument type, pricing, and bank remittance details — in the FIRMS portal format.
Valuation Compliance Review
Verification that the transfer price conforms to FEMA valuation norms — DCF for unlisted companies, SEBI pricing guidelines for listed companies.
Valuation Report Coordination
Coordination with a SEBI-registered Chartered Accountant for the DCF-based Fair Market Value certificate required for the FC-TRS filing.
AD Bank Coordination
Preparation of the complete AD bank submission package — KYC documents, share purchase agreement, FEMA compliance declarations — and coordination with the bank for sign-off.
FIRMS Portal Filing
End-to-end filing of Form FC-TRS on the RBI FIRMS portal through the company's AD bank, with all supporting documents attached.
Compounding for Late Filing
Preparation and filing of compounding applications with the RBI for FC-TRS filings that are already beyond the 60-day deadline.
Share Transfer Documentation
Preparation of the share purchase agreement, share transfer deed, board resolutions, and SH-4 form supporting the transfer transaction.
Regulatory Opinion
Written FEMA opinion on the permissibility of the proposed transfer structure, pricing, and instrument type, suitable for transaction due diligence.
Our Process
Transaction Review
We review the share purchase agreement, the parties involved (resident/non-resident classification), the instrument type, and the proposed pricing structure.
Valuation Check
The transfer price is verified against the applicable FEMA valuation norm. If a DCF certificate is required for unlisted companies, we coordinate its preparation.
AD Bank Package Preparation
A complete submission package for the AD bank is prepared — Form FC-TRS, KYC documents, share agreement, FEMA declarations, and valuation certificate.
AD Bank Coordination & Sign-Off
We coordinate with the company's AD bank for KYC verification and their endorsement of the FC-TRS submission.
FIRMS Portal Filing
Form FC-TRS is filed on the FIRMS portal through the AD bank. We track and share the RBI acknowledgement on completion.
Why It Matters
Frequently Asked Questions
Need to file FC-TRS for a share transfer involving a non-resident?
We verify valuation compliance, prepare the AD bank package, and file on the FIRMS portal within the 60-day deadline — complete FC-TRS compliance for your transfer transaction.
