Both forms report foreign investment in an Indian company, and both are filed on RBI’s FIRMS portal under the Single Master Form. Using the wrong one is a common error. The test is simple: did the company issue new shares, or did existing shares change hands?
The Core Distinction
| FC-GPR | FC-TRS | |
|---|---|---|
| Trigger | Fresh issue of equity instruments by the Indian company to a non-resident that counts as FDI | Transfer of existing equity instruments between a resident and a non-resident |
| Who files | The Indian company | The resident party, through its AD bank |
| Deadline | 30 days from the date of allotment | 60 days from the transfer or receipt or remittance of funds, whichever is earlier |
| Related filing | Advance Reporting Form within 30 days of receiving the funds | No separate advance reporting |
| Portal | FIRMS, Single Master Form | FIRMS, Single Master Form |
What FC-GPR covers
Equity shares, compulsorily convertible preference shares, compulsorily convertible debentures and share warrants issued to a non-resident. Other points:
- The clock runs from allotment, not from receipt of funds.
- Under the NDI Rules, shares must be allotted within 60 days of receiving the funds, or the money is refunded.
- The company files PAS-3 with the ROC as well, so cross-check share details against the FC-GPR draft.
What FC-TRS covers
A resident selling to a non-resident, or a non-resident selling to a resident. Transfers between two non-residents, or between two residents, are not reportable under it. Pricing rules differ by direction:
- Resident to non-resident: price not less than fair market value.
- Non-resident to resident: price not more than fair market value.
- Deferred consideration: up to 25% of the price can be deferred for up to 18 months, or held in escrow. Confirm the current conditions.
Related filings people forget
- Form DI: a downstream investment by an Indian company that has FDI, within 30 days of allotment.
- FLA return: annually by 15 July for entities with foreign investment.
Late filing
A delay is regularised by paying a late submission fee, which commentary says starts at ₹7,500, plus an amount linked to the sum involved and the delay. Larger or older breaches may need compounding. Check RBI’s circular for the current formula and caps.
Common mistakes
- Filing FC-GPR for a share transfer. The fix is to cancel it and file FC-TRS for the original transfer date, with a late fee if it is past 60 days.
- Counting 30 days from the receipt of funds.
- Missing the Advance Reporting Form.
- Leaving the FMV valuation certificate out of the pack.
- Not creating the Entity Master and Business User on FIRMS before the deadline.
Rule of thumb: new shares are FC-GPR; old shares moving between a resident and a non-resident are FC-TRS.
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