Foreign investment in India – Reporting in Single Master Form

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On June 27, 2018, RBI has released a notification on Reporting in Single Master Form, for which an online application FIRMS (Foreign Investment Reporting and Management System) has been introduced.  The first phase of reporting was already made available to Public from June 28 (at 1:00 pm) and July 12, 2018. The second phase would be available from 1st August 2018.

Benefits of this SMF:

  • ARF and FC-GPR would be merged into a single revised FC-GPR
  • Reporting of indirect foreign investment through form DI
  • Reporting of inflows in investment vehicles through Form InVi.
  • Reporting in FC-TRS, LLP-I, LLP-II, ESOP, DRR, and CN only in this mode

Who all should report here:

All the Entities shall provide data with respect to all foreign investments received, irrespective of the fact that the regulatory reporting to the Reserve Bank for the same has been made or not and whether the same has been acknowledged or not.

Definition of Entity:

  • A company within the meaning of section 1(4) of the Companies Act, 2013
  • A Limited Liability Partnership (LLP) registered under the Limited Liability Partnership Act, 2008 • A startup which complies with the conditions laid down in Notification No. G.S.R 180(E) dated February 17, 2016, issued by Department of Industrial Policy and Promotion, Ministry of Commerce and Industry, Government of India

Stringent Steps:

Indian entities not complying with these instructions will not be able to receive foreign investment (including indirect foreign investment) and will be treated as non-compliant with Foreign Exchange Management Act, 1999 (FEMA) and regulations made thereunder and liable for action as laid in FEMA or the regulations made thereunder.

You may also visit the below link for online submission released by RBI: https://rbidocs.rbi.org.in/rdocs/FEMAMASTER/PDFs/USERMANUAL270620189E89DF88A9574C0E9B5CE09A14AA263E.PDF

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