Alerts & Updates

Update | Reporting of foreign investment in a Single Master Form

Corporate & Commercial | Jun 8, 2018

RBI, vide a Circular dated June 7, 2018 bearing Circular No. RBI/2017-18/194 (A.P (DIR Series) Circular No. 30) (available here), has provided a Single Master Form (“SMF”) for reporting of foreign investments in India. The SMF consolidates the following forms:

Form Purpose
Form FC-GPR Reporting of issue of capital instruments by an Indian company to a person resident outside India
Form FC-TRS Reporting of transfer of capital instruments between a person resident outside India and a person resident in India
Form LLP-I Reporting of FDI in LLP through capital contribution and profit shares
Form LLP-II Reporting of disinvestment/ transfer of capital contribution and profit shares in LLP
Form ESOP Reporting of issue of ESOPs / sweat equity shares/ shares against exercise of ESOP by an Indian company to an employee resident outside India.
Form CN Reporting of issue or transfer of convertible notes.
Form DRR Reporting of issue/transfer of Depository Receipts.
Form DI Reporting of downstream investment (indirect foreign investment) in a company or LLP.
Form InVi Reporting of investment by a person resident outside India in an Investment vehicle.

The SMF would also provide an online facility for reporting the total foreign investment in an (i) Indian entity; and (ii) Investment vehicle (in a specified format, available here).

Prior to the SMF facility being implemented, Indian entities are initially required to provide data on the total  foreign investment received by them on an interface on the RBI website. This interface which would be available from June 28, 2017 to July 12, 2018 (the format in which total foreign investment would have to be reported is available here).

Please note that Indian entities not complying with this pre-requisite reporting requirement on the RBI interface would not be permitted to receive foreign investment (including indirect foreign investment) and would be non-compliant under the Foreign Exchange Management Act, 1999 and regulations made thereunder.

Indian entities have also been advised by the RBI to keep the data ready, so that the reporting on the RBI interface can be completed within the deadline.