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FDI & FEMA Compliance for clients in Cyprus

Many Indian companies have Cypriot shareholders from the years when Cyprus was a favoured holding jurisdiction, and their compliance often needs attention.

Updated Reviewed by our legal team

FDI & FEMA Compliance for clients in Cyprus
In short

Investment by a Cypriot company in an Indian company is foreign direct investment under FEMA and the Non-Debt Instruments Rules 2019. Share allotments must be reported in Form FC-GPR within 30 days, transfers in Form FC-TRS within 60 days, and the annual return on foreign liabilities and assets filed every year. Missed filings can usually be regularised by paying a late submission fee or by compounding.

Document route
Cypriot certifying officer and apostille, or Indian High Commission attestation
Time difference
IST is 2h30 ahead of Cyprus in summer and 3h30 in winter
Law
FEMA 1999 and NDI Rules 2019
New shares
FC-GPR within 30 days of allotment

FDI & FEMA Compliance from Cyprus: how it works

We review the Indian company's foreign investment history, identify missed or defective filings, and regularise them through late submission fees or compounding applications to the RBI. We also check pricing compliance for past issues and transfers.

For restructuring, such as moving a Cypriot holding into another jurisdiction or into India, we plan the FEMA steps, the tax position under the 2016 treaty and its grandfathering, and any approvals needed if beneficial ownership changes.

We also advise on downstream investment by Indian companies that are foreign-owned or controlled because of a Cypriot parent.

What clients in Cyprus should know

  • File FC-GPR within 30 days of allotment.
  • Check grandfathering before selling pre-2017 shares.
  • Compounding is available for most contraventions.

Step by step from Cyprus

  1. Video consultation

    A call at a time that suits Cyprus, after we have read your documents.

  2. Documents signed in Cyprus

    Cypriot certifying officer and apostille, or Indian High Commission attestation

  3. Work in India

    Our team files, appears and follows up in India, and shares scans of everything filed.

  4. Result and handover

    Certified copies and originals are couriered to you in Cyprus where needed.

The full guide

This page covers what changes when you are in Cyprus. For the law, the documents and the step-by-step procedure, read our main page on FDI & FEMA Compliance, or see all services for clients in Cyprus and the Doing Business in India practice area.

Please note: this page explains the law and procedure in general terms as on 12 November 2026. Fees, limits and timelines change, and the facts of each case matter, so take advice on your own papers before acting.

Questions from clients in Cyprus

We missed FC-GPR filings years ago. What now?

They can usually be regularised with a late fee or compounding.

Does a change in the Cypriot parent's owners need approval?

Only if new beneficial owners are from a land-border country.

Are gains on pre-2017 shares taxable?

Generally not in India, under the grandfathering provisions.

Tell us about your matter

Send the papers you have. We reply to clients in Cyprus within one working day.

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