Introduction
Foreign Currency Transfer Report Scheme – Timely Reporting of Foreign Investments Transfer
FCTRS (Foreign Currency Transfer Report Scheme) is a regulatory filing required when there is a transfer of shares or capital instruments held by a foreign investor in an Indian company to another foreign investor or resident, involving foreign currency consideration. The scheme ensures RBI monitoring and regulatory compliance of share transfers involving foreign investments.
Legal & Regulatory Framework
Regulator
Reserve Bank of India (RBI)
Regulation
Foreign Exchange Management (Transfer or Issue of Security by a Person Resident Outside India) Regulations, 2017 (FEMA FDI Regulations)
Purpose
To report transfer of shares by foreign investors in an Indian company
Documents Required for FCTRS Filing
- Share transfer deed executed between parties
- Board resolution approving transfer (if applicable)
- KYC documents of transferee
- Valuation certificate (if transfer is at premium or discount)
- Bank certificate evidencing receipt of consideration (if foreign currency)
- Copy of share certificates
- Details of transferor and transferee (FIRC, PAN, address proof)
Whenever there is a transfer of shares or capital instruments by a foreign investor to:
- Another foreign investor OR
- A resident (Indian) entity or individual
- The transfer involves consideration in foreign currency or is subject to FEMA regulations
- Reporting is required to the RBI to maintain transparency on foreign investments and transfers
Step 1: Share Transfer Agreement
Execute a legally valid share transfer agreement between the transferor and transferee
Step 2: Obtain Approvals (if applicable)
Check whether the share transfer requires prior approval from RBI or the Government of India as per FDI policy
Obtain necessary approvals if mandated
Step 3: Prepare Documents
Share transfer deed
Board resolutions approving share transfer (transferor and transferee companies if applicable)
KYC and due diligence documents of transferee
Copy of share certificate(s)
Valuation report (if applicable)
Bank certificate evidencing remittance or consideration
Step 4: File FCTRS Report
File FCTRS report on the RBI’s Foreign Investment Reporting and Management System (FIRMS) portal
Provide details of transferor, transferee, number of shares transferred, consideration, and other relevant details
Upload supporting documents and declarations
Submit for RBI acknowledgment