Foreign-owned company · Compliance planning
Annual Compliance Calendar for a Foreign-Owned Indian Subsidiary
An Indian subsidiary of an overseas parent has several compliance calendars running at the same time. Company-law filings, tax returns, GST, payroll and foreign-investment reporting follow different triggers. A useful calendar shows not only the deadline, but also what starts the clock, who owns the task and what evidence must be retained.
Quick answer
How should we build a compliance calendar for an Indian subsidiary?
Create separate lists for incorporation-stage actions, event-based filings and recurring monthly, quarterly and annual obligations. Assign an owner, a due date, a document checklist and a backup reviewer to each item. Check current MCA, RBI, Income Tax and GST guidance for the relevant year because applicability and dates depend on the company’s facts and rules in force.
This page is a planning framework, not a universal list of filings. For the actions immediately after incorporation, use our post-incorporation checklist. This calendar focuses on how to organise obligations across the year.
1. Put event-based deadlines in first
Event-based filings do not wait for the year-end calendar. They can be triggered by incorporation, share allotment, a transfer of shares, a new employee, a related-party transaction or a change in the company’s registered details.
| Trigger | What to check | Calendar action |
|---|---|---|
| Company incorporated | Initial board actions, auditor appointment, registered-office and commencement requirements, as applicable | Create a first-30-days task list and a separate tracker for any longer statutory window |
| Foreign investment or share allotment | Remittance evidence, issue records, valuation and RBI/FEMA reporting such as FC-GPR where applicable | Record the actual transaction date and confirm the deadline under current RBI directions |
| Share transfer or ownership change | Applicable pricing, eligibility, corporate approvals and FC-TRS or other reporting, where required | Open a transaction-specific compliance task before completing the transfer |
| New business activity or hiring | GST, payroll, labour, state registrations, tax withholding and contract implications | Review requirements before the activity or employment begins |
| Cross-border related-party transaction | Transfer pricing, supporting agreements, invoices, evidence of services and year-specific reporting | Keep transaction records throughout the year; do not reconstruct them only at tax-return time |
The RBI’s foreign-investment directions and the current filing guidance should be checked for the actual transaction. See also our guide to funding an Indian subsidiary from the US.
2. Organise the recurring calendar by frequency
Keep monthly and quarterly tasks separate from annual corporate filings. The following is a structure for your tracker, not a statement that every item applies to every company.
| Frequency | Items to assess | What to retain |
|---|---|---|
| Monthly | Bookkeeping close, GST returns where registered, tax deducted at source, payroll and applicable employee contributions | Ledgers, invoices, payroll registers, payment challans and filed-return acknowledgements |
| Quarterly or periodic | Tax statements, advance tax, board meetings and other activity- or registration-specific filings | Working papers, board minutes, reconciliations and submission receipts |
| Annual | Statutory audit, annual general meeting, financial statements and annual return filings, income tax, and FLA Return where applicable | Signed accounts, audit report, minutes, filed forms and tax computations |
| Conditional | Transfer pricing, GST annual filings, external commercial borrowing reports, import/export, sector and state requirements | Evidence that the obligation applies or the documented basis for treating it as not applicable |
3. Add key annual planning dates, then verify the current year
- FLA Return: RBI guidance generally uses 15 July for the annual return covering the position at the preceding 31 March. Check eligibility and current FLAIR instructions, including any provisional or revised filing process.
- Annual general meeting: plan around the Companies Act deadline that applies to the company and financial year. The first AGM can follow a different window from later AGMs.
- Financial statements and annual return: schedule the applicable ROC filings from the AGM date and confirm the form and filing window under current MCA rules.
- Income tax and transfer pricing: check the applicable tax year, taxpayer category, transaction profile and current form. Do not copy last year’s deadline or form number without verification.
- GST and payroll: due dates can depend on registration, filing frequency, state and the relevant scheme. Include monthly tasks only where they apply.
Official starting points include the Ministry of Corporate Affairs, Reserve Bank of India, Income Tax Department and GST portal. Check the applicable instructions and any official extensions before filing.
4. Give every task an owner and evidence trail
For each calendar item, record these fields:
- Filing or action name and the law, registration or transaction that makes it applicable.
- Trigger date, statutory due date, internal deadline and the source used to confirm the date.
- Responsible person, reviewer, external adviser and backup contact.
- Required documents, dependencies, payment status and filing acknowledgement.
- Last-reviewed date and the next date to recheck the rule or portal instructions.
A calendar works best when the finance team, company secretary, payroll provider and overseas parent agree who supplies each document and when. If the Indian subsidiary has intercompany transactions, coordinate the accounting evidence with the parent’s finance team during the year. Our FLA Return and transfer-pricing guide, payroll guide and GST guide cover those workstreams separately.
5. Review the calendar when the business changes
Revisit the tracker when the company hires its first employee, registers for GST, begins exports, receives additional investment, transfers shares, takes a loan, adds a new state location or starts charging the overseas parent for services or intellectual property. These changes can create obligations that do not appear in a generic annual calendar.
For a wider first-year action list, see our post-incorporation compliance checklist. For statutory audit and reporting questions, use our audit requirements guide.
Frequently asked questions
What compliance does a foreign-owned Indian subsidiary need to track?
Depending on its activities and transactions, a subsidiary may need to track company-law filings, statutory audit, income tax, GST, payroll obligations, foreign-investment reporting and transfer-pricing requirements. The exact list depends on the company, registrations, state, transactions and rules for the relevant year.
When is the FLA Return due?
RBI guidance generally sets 15 July as the annual FLA Return deadline for eligible Indian entities reporting the position as at the preceding 31 March. Applicability and any provisional or revised filing process depend on the current RBI instructions and the entity’s facts.
When should FC-GPR be added to the calendar?
FC-GPR is associated with an Indian company issuing equity instruments to a person resident outside India. The reporting clock is linked to the share allotment, not simply the date the company was incorporated. Confirm the transaction, documents and current RBI filing instructions before setting the deadline.
Do all foreign-owned subsidiaries need GST and transfer-pricing filings?
No single answer applies to every company. GST obligations depend on the business, supplies, turnover, location and registration status. Transfer-pricing analysis or reporting may be required for relevant transactions with associated enterprises. Assess each obligation separately rather than assuming foreign ownership alone triggers every filing.
Can we use the same compliance dates every year?
Use recurring dates as planning prompts, not as a substitute for checking current rules. Tax forms, due dates, thresholds, extensions and reporting processes can change. Reconfirm deadlines for the relevant financial or tax year and record any official extension.
Prepared by AU Corporate’s CA-led advisory team. This guide is general information, not legal, tax or company-secretarial advice for a particular entity. Filing requirements and deadlines can change; confirm the current position with the relevant authority or qualified adviser before acting.