TaxTMI 
TaxTMI 
In the context of a bill-to-ship-to model where goods have been ordered and imported from a foreign country for our customers, with the payment made by us, but the goods have not been received by us (they have been received directly by our customers), what are the implications under the FEMA (Foreign Exchange Management Act) regulations?
Import of goods in bill to ship to model in FEMA
08 Aug 2024 
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Merchanting trade classification under FEMA may differ from bill-to-ship-to import arrangements, affecting documentary compliance.
The issue is whether a bill-to-ship-to arrangement-where an Indian entity orders and pays for foreign goods that are delivered directly to its Indian customers-qualifies as merchanting trade under FEMA or as an import, with reference to AP (DIR Series) Circular No. 115 and FEMA's documentary and compliance requirements. (AI Summary)
The issue is whether a bill-to-ship-to arrangement-where an Indian entity orders and pays for foreign goods that are delivered directly to its Indian customers-qualifies as merchanting trade under FEMA or as an import, with reference to AP (DIR Series) Circular No. 115 and FEMA's documentary and compliance requirements. (AI Summary)