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FEMA Reporting, Foreign Remittances and Export Compliance for D2C Brands
RBI reporting for foreign investment (FC-GPR, FC-TRS, FLA), Form 15CA and 15CB for foreign remittances, and export documentation checks.
A D2C brand meets FEMA the first time it takes foreign investment, pays a foreign software or advertising company, or ships an order abroad. Each of these has its own RBI or income-tax reporting, and the time limits run from dates that are easy to miss.
Foreign investment reporting (RBI FIRMS)
- Entity Master set-up on the FIRMS portal
- Form FC-GPR for shares allotted to foreign investors, with the KYC, valuation certificate and allotment records
- Form FC-TRS for transfers of shares between residents and non-residents
- The annual Foreign Liabilities and Assets (FLA) Return, due each year by 15 July
- Late Submission Fee (LSF) working and regularisation support where a filing was missed
Foreign remittances
- Form 15CA (Parts A, B, C and D) for payments to foreign SaaS, advertising and supplier companies
- Form 15CB, certified by a CA, with a review of the tax treaty (DTAA) position, the tax residency certificate (TRC) and Form 10F
Exports
- Courier exports under CSB-V and shipping bill checks
- Export realisation tracked against EDPMS, with DGFT e-BRC records
What's included
- A filing calendar for every FEMA return that applies to your company
- Documents gathered and checked before each filing
- Remittance certificates prepared as payments arise
Late fees and compounding are decided by the RBI; any outcome depends on the facts of the case.
Common questions
When is Form FC-GPR filed?
Form FC-GPR is filed on the RBI FIRMS portal after a company allots shares to a person resident outside India, within the time limit counted from the date of allotment. A late filing can be regularised by paying a Late Submission Fee, within the limits the RBI sets.
Who has to file the FLA Return?
An Indian company or LLP that has received foreign direct investment, or made an overseas investment, files the annual Foreign Liabilities and Assets (FLA) Return with the RBI, including in years with no new investment.
When are Form 15CA and Form 15CB needed?
Form 15CA is filed before many payments to a non-resident, such as for foreign software, advertising or supplier services. Form 15CB is a CA's certificate on the tax position of the payment, including any tax treaty benefit, and is needed for larger taxable remittances.