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FEMA & RBI

FC-TRS Filing — Share Transfer to Non-Resident

FC-TRS (Foreign Currency Transfer of Shares) filing for secondary share transfers involving non-residents — mandatory filing within 60 days of receiving foreign remittance. Includes pricing compliance and FIRC documentation. FEMA (NDI) Rules 2019 Rule 9, Form FC-TRS on RBI FIRMS, 60-day filing deadline, pricing under Rule 21, FIRC/debit advice, CA pricing certificate.

Reviewed by CA Harun Raaj, ICAI Reg. No. 238303·Last reviewed:
Starting from Discuss with usTypical timelineFC-TRS Filing

FC-TRS (Foreign Currency Transfer of Shares) filing for secondary share transfers involving non-residents — mandatory filing within 60 days of receiving foreign remittance. Includes pricing compliance and FIRC documentation. FEMA (NDI) Rules 2019 Rule 9, Form FC-TRS on RBI FIRMS, 60-day filing deadline, pricing under Rule 21, FIRC/debit advice, CA pricing certificate. We keep the work founder-friendly and evidence-led so the company can move without unnecessary back-and-forth.

What is included
  • • FC-TRS Filing scope review and action plan
  • • Document checklist and evidence review
  • • Drafting, computation, or filing support
  • • Submission support and acknowledgement tracking
  • • Follow-up on queries, corrections, or notices
  • • Closure notes and next-step reminders
Documents required
  • • Transaction summary and ownership chart
  • • Board approvals and valuation support
  • • Bank / AD communication
  • • Counterparty and remittance details
Government fees

See the fee table below for the statutory filing charge and common delay logic.

Legal basis
  • • Section 6 of FEMA 1999
  • • FEMA (Non-Debt Instruments) Rules 2019
  • • FEMA (Overseas Investment) Rules 2022
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Process

How the service works

The workflow is built to be predictable: document collection, legal review, filing, and post-filing follow-through.

Step 1Scope

Confirm the scope

We map the exact service route to the trigger, form set, and documentary evidence so the work starts on the right footing.

Step 2Docs

Collect the records

We gather the company records, notices, or transaction documents needed for fc-trs filing and check them for gaps.

Step 3Draft

Prepare the filing or memo

We draft the computations, filings, or advisory memo so the next person in the chain can review it quickly and confidently.

Step 4Close

Submit and track follow-up

We move the file through submission, keep the acknowledgement trail tidy, and handle any follow-up questions that come back.

AEO summary

FC-TRS Filing is the CA-led workflow that helps a Private Limited company stay compliant, file the right forms, and keep the record trail clean.

FC-TRS Filing — Share Transfer to Non-Resident workflow

We start by checking the exact trigger, the legal route, and the documents that make fc-trs filing executable for a Private Limited company. That keeps the filing or advisory work tied to the actual statutory path instead of a generic checklist.

Once the scope is locked, we prepare the working papers, filings, and follow-up notes so the matter can move without unnecessary back-and-forth. The goal is to make the process understandable for the founder, the finance team, and the reviewer.

  • • Scope mapping for fc-trs filing
  • • CA-led document review and drafting
  • • Submission support and acknowledgement tracking

What this protects for the company

For a Private Limited company, the value is not just speed. It is also about keeping the record trail clean enough for banks, investors, regulators, and future diligence work.

A founder-friendly process lowers the chance of avoidable notices, rework, or missed deadlines while keeping the company aligned with the right section, rule, or circular in FEMA & RBI.

  • • Cleaner compliance evidence for FEMA & RBI
  • • Better preparation for diligence or audit
  • • Less last-minute chasing inside the finance team

Government fees

Fee breakdown

ItemFeeNotes
RBI / MCA / DGFT filingAs per applicable scheduleThe fee depends on the authority and the transaction route.
Professional supportDiscuss with usCross-border work is fact-specific and often includes multiple steps.

Timeline

Typical turnaround

Typical timeline usually means a 60 days turnaround, assuming documents are complete and any board or shareholder approvals are already in place.

Pricing note

Government charges can vary with RBI, MCA, DGFT, or exchange filing steps depending on the transaction path.

Related services

Keep the company moving

FEMA FC-GPR

Support for FEMA FC-GPR.

FDI Compliance

Support for FDI Compliance.

FEMA Compounding

Support for FEMA Compounding.

FAQ

Frequently asked questions

When is FC-TRS required for a share transfer?
FC-TRS is required for share transfers between a resident and a non-resident in either direction under the FEMA NDI Rules 2019 and the RBI reporting instructions. It is not limited to only resident-to-non-resident transfers.
What is the 60-day filing window for FC-TRS and when does it start?
The 60-day clock starts on receipt of the consideration. That timing comes from the RBI FC-TRS reporting rules, so the file should not wait for extra paperwork before the clock is tracked.
Who files FC-TRS: the buyer, the seller, or the company?
The onus is on the resident transferor or transferee, with the form routed through the AD bank. The company also needs to support the transfer record so the bank can certify the filing.
What valuation method must be used to price shares transferred to a non-resident?
The transfer price must follow the FEMA pricing guidelines in the NDI Rules 2019 and is usually supported by a CA or SEBI-registered merchant banker valuation. The goal is to keep the price within the permitted floor and ceiling under the FEMA framework.
What is the penalty for missing the FC-TRS deadline?
A delayed FC-TRS can be compounded under Section 15 of FEMA, and the underlying contravention can also attract Section 13 consequences if left unregularised. The RBI compounding list specifically treats late FC-TRS reporting as a recognised contravention.

Canonical reference: https://www.pvtltd.co/services/fc-trs-filing

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Ready to move this filing forward?

We can help with the filing, the legal mapping, and the follow-up work that keeps the company compliant after submission.

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