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RBI Reporting, zero notices.

Inbound FDI, outbound ODI, ECB loans, share transfers — every cross-border flow has a clock, a form, and a penalty. We run the RBI compliance calendar for Indian subsidiaries of foreign companies so no filing ever slips.

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?Quick Answer

What RBI filings does my Indian entity need?

If you have any foreign shareholding, you need: FC-GPR within 30 days of share issue, FC-TRS within 60 days of any transfer, annual FLA by 15 July, and (if applicable) ODI Form FC, APR, and ECB reporting. All filings go through the FIRMS portal via your AD bank. We manage the entire calendar.

FC-GPR Window
30 days
FLA Return
15 July
Late Fee Risk
Up to 3x
Key Facts at a Glance
RegulatorReserve Bank of India
PortalFIRMS (firms.rbi.org.in)
FC-GPR deadline30 days from allotment
FC-TRS deadline60 days from transfer
ODI APRBy 31 December
ECB Form ECB-2Monthly, by 7th
What we handle

One calendar. Every FIRMS form. Filed clean.

We become the compliance owner for your Indian entity — entity master maintained, valuations coordinated, AD bank handled, certificates issued. You see one dashboard; the regulator sees clean filings.

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01
Entity Master & Business User Setup

Initial FIRMS registration, entity master creation, and business user activation through your AD bank — the foundation for every future filing.

02
Inbound FDI: FC-GPR & SMF

Valuation, CS certificate, CA certificate, KYC of remitter, FIRC collection, and Form FC-GPR filing on FIRMS within the 30-day window.

03
Secondary Transfers: FC-TRS

Share transfers between resident and non-resident — pricing guidelines check, valuation, Form FC-TRS filing within 60 days of the earlier of transfer or consideration.

04
Annual FLA Return

Foreign Liabilities and Assets return filed every 15 July for every entity with foreign investment. We collect data, reconcile balances, and file in time to avoid LSF.

05
ODI & APR Filings

Form FC for outbound investments, Annual Performance Reports by 31 December, and disinvestment reporting — for Indian groups investing into JVs and WOSs abroad.

06
ECB & Trade Credit Reporting

LRN application for new ECBs, monthly Form ECB-2 returns, trade credit reporting (Form TC), and end-use monitoring per the ECB Master Direction.

Compliance Calendar

Key checkpoints. Miss none.

Statutory · India
Within 30 daysPer event
FC-GPR after every fresh share issue to a non-resident
Within 60 daysPer event
FC-TRS after every share transfer involving a non-resident
Monthly · 7thRecurring
ECB-2 return for every active ECB borrowing
15 JulyAnnual
Annual FLA Return for all foreign-invested entities
31 DecemberAnnual
ODI Annual Performance Report for foreign JV / WOS
Pre-dealAdvisory
Sectoral cap & pricing guideline confirmation before any investment
What to keep ready

Documents we'll ask for.

A clean document set cuts our turnaround in half. Send what you have — we'll request the rest in a single consolidated checklist.

Certificate of Incorporation & MoA/AoA
Latest certified copies of the Indian entity.
Board & shareholder resolutions
Authorising the share issue, transfer, or borrowing.
Valuation report
From a SEBI-registered merchant banker or qualified CA.
FIRC and KYC of remitter
Foreign Inward Remittance Certificate from your AD bank.
Share allotment / transfer documents
Form PAS-3 (allotment), share transfer deeds, register of members.
Audited financials
Latest year for FLA, ODI APR, and ECB reporting.
Loan agreement (ECB)
Signed agreement, term sheet, and end-use declaration.
Prior RBI filings
Acknowledgments of past FC-GPR, FC-TRS, FLA — for continuity.

Filings overdue?

Send us your last 3 years of FIRMS filings. We will return a one-page gap report with exposure quantified — and the cleanest path to regularise via LSF or compounding.

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Frequently Asked Questions

Answered by CAs.

What is the FIRMS portal and who must register?+
FIRMS (Foreign Investment Reporting and Management System) is the RBI's single window for all foreign investment reporting. Any Indian company receiving FDI, issuing shares to non-residents, or undertaking related-party share transfers must register the entity master and file FC-GPR, FC-TRS, ESOP, and LLP-I/II as applicable.
What is Form FC-GPR and when is it due?+
Form FC-GPR (Foreign Currency – Gross Provisional Return) reports the issue of equity, CCPS, or CCDs to a person resident outside India. It must be filed on the FIRMS portal within 30 days of share allotment, with valuation certificate, CS certificate, and CA certificate.
What is Form FC-TRS?+
Form FC-TRS reports the transfer of shares between a resident and a non-resident (or vice versa) of an Indian company. It must be filed by the resident party within 60 days of the transfer or receipt of consideration, whichever is earlier.
What is the FLA Return and who must file it?+
The Annual Return on Foreign Liabilities and Assets (FLA) must be filed by every Indian company, LLP, AIF, or partnership that has received FDI or made overseas direct investment (ODI). Due on or before 15 July every year. Late filing attracts compounding penalties under FEMA.
What is ODI and what reporting is required?+
Overseas Direct Investment (ODI) covers any investment by an Indian entity in a foreign JV or wholly-owned subsidiary. Reporting requires Form FC, Annual Performance Report (APR by 31 December), and the new ODI 2022 framework with Form FC-ODI filings through AD banks.
What is ECB and how is it reported?+
External Commercial Borrowing (ECB) is any foreign-currency loan availed by an Indian entity from a non-resident lender. Reporting includes the Loan Registration Number (LRN) application, monthly Form ECB-2 returns, and end-use compliance under the RBI Master Direction on ECB.
What are the penalties for delayed FIRMS filings?+
Late Submission Fee (LSF) under the FEMA framework applies: ₹7,500 + (transaction amount × number of years × 0.025%), capped at the transaction amount. Beyond LSF window, compounding before the RBI with penalties up to 3x the transaction value.
Can a foreign company invest in any Indian sector?+
Most sectors are under the automatic route (100% FDI permitted without prior approval). Sectors like defence, telecom, broadcasting, insurance, multi-brand retail, and pharmaceuticals (brownfield) need government approval through the FDI portal. We confirm sectoral caps and routes before the investment.
What is the difference between FDI and FPI?+
Foreign Direct Investment (FDI) is a strategic stake (≥10% of equity, or any stake giving management influence). Foreign Portfolio Investment (FPI) is below 10% and made through a SEBI-registered FPI. Reporting forms, lock-ins, and exit rules differ — we structure the investment for the right route.
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