Compliance Calendar for Foreign-Owned Indian Companies: Tax Year 2026-27

Delhi Legal Company · Updated August 2026 · 19 min read

A generic Indian compliance calendar will get your subsidiary about seventy percent of the way there. The remaining thirty percent — FEMA reporting, transfer pricing, non-resident withholding, the FLA return — is where foreign-owned companies actually get penalised, because those filings have no domestic equivalent and no accountant flags them by habit. This calendar is built for that gap.

The short version

• The Income-tax Act, 2025 replaced “Financial Year” and “Assessment Year” with a single concept: Tax Year. TY 2026-27 runs 1 April 2026 to 31 March 2027. EZTax
• Your subsidiary carries four overlapping calendars — Income Tax, GST, MCA/Companies Act, and FEMA/RBI — plus labour law and, if you trade goods, DGFT.
• The filings that are unique to foreign ownership: FC-GPR, FC-TRS, FLA, ECB-2, Form 3CEB, Form 27Q, Form 145/146. None of these exist for a purely domestic company.
• AOC-4 and MGT-7 attract ₹100 per day in additional fees with no cap. A twelve-month delay is not a fine; it is an open-ended liability. Legalsuvidha
• Warning on DIR-3 KYC: most published 2026-27 calendars, including several cited in this article, still show DIR-3 KYC due 30 September annually. That position changed with effect from 31 March 2026. See section 8.

1. Why foreign-owned subsidiaries default more often

Not through negligence. Through structural blind spots. Four recur:

The group treats India as a reporting line, not a legal entity. Group finance consolidates the numbers monthly and assumes compliance follows. It does not. India’s obligations attach to the Indian entity independently of anything the group does.

The local accountant covers tax and GST, and nothing else. A competent Indian accountant will file GSTR-3B and the income tax return flawlessly and never mention the FLA return, because their other clients do not have foreign shareholding.

FEMA filings are event-driven, not date-driven. FC-GPR runs from the date shares are allotted. FC-TRS runs from the date of transfer. There is no annual date to put in a calendar — the clock starts when a corporate action happens, often before anyone tells the compliance team it happened.

Nobody owns the calendar. The India CFO reports to a regional finance head who reports to group. The company secretary is an outsourced firm. The auditor is a third party. Between them, the FLA return in July belongs to no one.

2. Master calendar — Tax Year 2026-27 at a glance

3. The monthly rhythm

These recur every single month and account for most of the actual workload.

The ECB-2 trap. If your subsidiary has taken a loan from its parent, that is almost certainly an external commercial borrowing, and it carries a monthly RBI return filed through the AD bank. Companies that structured a shareholder loan two years ago and forgot the ongoing reporting are surprisingly common. Check whether you have a Loan Registration Number. If you do, you owe monthly returns.

4. The filings unique to foreign ownership

This is the section that distinguishes your calendar from your domestic competitor’s.

FLA Return — 15 July, every year

The Foreign Liabilities and Assets return is filed with the RBI by every Indian company that has received FDI or made overseas investment in any previous year, including years in which there was no fresh transaction. It is based on audited figures where available, and on unaudited figures with a revised filing later where the audit is not complete.

This is the single most commonly missed filing by foreign-owned subsidiaries. It is not a tax filing, not an MCA filing, and sits with the RBI — so it falls between every advisor’s remit unless someone owns it explicitly.

FC-GPR — within 30 days of allotment

When the Indian company issues shares to a non-resident, Form FC-GPR must be filed on the RBI’s FIRMS portal within 30 days of allotment. The clock runs from the allotment date, not from the date funds were received and not from the date the board decided.

The supporting set typically includes the FIRC and KYC from the AD bank, a valuation certificate, a company secretary’s certificate, and the board resolution. Assembling that takes time. Start on the day of allotment, not on day 25.

FC-TRS — within 60 days

Filed where shares are transferred between a resident and a non-resident, in either direction. The 60 days run from the receipt or remittance of funds. Secondary transfers — a founder selling to the foreign parent, or the parent selling down to a local partner — trigger this and are frequently missed because they feel like private transactions rather than regulatory events.

Form 3CEB — 31 October

The transfer pricing accountant’s report. Required where the company has entered into international transactions with associated enterprises — which, for a foreign-owned subsidiary, means almost always. Management fees, royalty, cost recharges, intercompany loans, sale or purchase of goods with the group, guarantees: all are international transactions with an associated enterprise. Legalsuvidha

Where Form 3CEB is filed, the income tax return due date extends to 30 November. Do not read that as extra time — the transfer pricing study that supports the certificate needs benchmarking work that begins in the summer, not in November. CORAA AI

Form 27Q — quarterly

The withholding return for payments to non-residents. Due 31 July, 31 October, 31 January and 31 May. Separate from Form 26Q for domestic deductions. Every payment to your parent — royalty, management fee, interest, dividend — reports here. Legalsuvidha

Form 145 and Form 146 — per remittance

Under the Income-tax Act, 2025, Form 15CA and Form 15CB have been renumbered. Form 145 is the remitter’s declaration; Form 146 is the Chartered Accountant’s certificate required where the chargeable remittance to a payee exceeds ₹5 lakh in the tax year. These are event-driven, filed before each outward remittance, and the bank will not release funds without the Form 145 acknowledgement. EZTax

Annual Performance Report — 31 December

Only if your Indian company itself holds an overseas subsidiary or joint venture. Rare for a downstream subsidiary, but relevant where the Indian entity has become a regional holding company.

5. MCA and Companies Act obligations

DPT-3 and the parent loan. Many foreign-owned subsidiaries are funded partly by intercompany loan. That amount has to be reported in DPT-3 by 30 June each year, and it also usually sits within the ECB framework with its own monthly reporting. Two entirely separate regimes, one transaction. Neither advisor assumes it is theirs.

6. Income tax dates in detail

Advance tax. 15 June, 15 September, 15 December and 15 March. Foreign-owned subsidiaries commonly under-provide the first instalment because June arrives before the previous year’s audit is closed. Interest for shortfall accrues regardless. Legalsuvidha

Tax audit report. 30 September. RegisterKaro

Income tax return.

TDS quarterly returns. Form 26Q for domestic deductions and Form 27Q for non-resident payments, both due 31 July, 31 October, 31 January and 31 May.

7. GST

Two GST issues specific to foreign-owned companies: import of services from the parent attracts GST under reverse charge, and it is routinely missed on management fee and software recharges. And reconciliation for GSTR-9/9C should start in October, not December — group-level intercompany entries are exactly the items that fail reconciliation. Legalsuvidha

8. DIR-3 KYC — do not rely on the standard calendars

Almost every compliance calendar published for FY 2026-27 states that DIR-3 KYC must be completed by 30 September, and that the DIN deactivates from 1 October if not filed, with reactivation costing ₹5,000 per DIN. RegisterKaroLegalsuvidha

That reflects the pre-amendment position. With effect from 31 March 2026, the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025 replaced annual Director KYC with a triennial cycle, and merged the two forms into a single Form DIR-3 KYC Web. Separately, any change in a director’s mobile number, email address or residential address must now be intimated within 30 days — a standalone obligation that runs independently of the three-year cycle.

Commentary on which year your first filing under the new cycle falls in has been inconsistent. Verify each director’s DIN status directly on the MCA portal and confirm the due year with your Company Secretary rather than relying on a published calendar — including the table in section 2 of this article, which flags the item without asserting a date.

9. Labour law and payroll

For subsidiaries with seconded employees from the parent, payroll is not a routine item. The characterisation of a secondment affects withholding, permanent establishment exposure, and social security — and has produced substantial Indian litigation. Treat it as a tax question, not an HR one.

10. Where foreign-owned companies actually get caught

1. FLA return, 15 July. No advisor’s default remit. Missed more than any other filing.
2. FC-GPR beyond 30 days. The clock runs from allotment, not from funds received.
3. ECB-2 monthly returns on a shareholder loan nobody remembers structuring as an ECB.
4. Reverse charge GST on management fees and software recharges from the parent.
5. TDS at accrual, not at payment. A March year-end accrual to the parent triggers withholding in March.
6. Form 3CEB scoped too narrowly, omitting cost recharges or intercompany guarantees.
7. DPT-3 omitting the parent loan.
8. AOC-4 and MGT-7 late — and the ₹100/day runs uncapped while the group debates who signs.
9. Director details stale on MCA, so notices go nowhere.
10. IEC annual update missed, deactivating the code on 1 July and stranding consignments at port.

11. Ownership matrix — assign each of these to a name

The row in bold is the point of this article. Put a name in it.

12. Quarterly checklist for the India CFO

Every quarter:
☐ Board meeting held, minutes signed, 120-day gap maintained
☐ Advance tax instalment computed and paid
☐ Form 26Q and Form 27Q filed
☐ Intercompany balances reconciled with the group
☐ Any share allotment or transfer in the quarter checked against FC-GPR / FC-TRS deadlines
☐ Any change to director address, email or mobile checked against the 30-day KYC obligation
☐ ECB-2 returns filed for each month, if applicable

Annually, in April:
☐ LUT filed for the new financial year
☐ IEC annual update calendared for the 1 April–30 June window
☐ Statutory auditor engagement confirmed
☐ Transfer pricing scoping call held — list every international transaction with the group
☐ Director register refreshed: DIN status, KYC due year, DSC expiry, registered email and mobile
☐ Compliance ownership matrix reviewed, with a named owner for FEMA

---

Running an Indian subsidiary from overseas? Delhi Legal Company operates the full compliance stack for foreign-owned Indian companies — tax, GST, ROC, payroll and, critically, the FEMA and transfer pricing filings that fall between advisors. One calendar, one owner, one monthly report to the group.

---

13. Frequently Asked Questions

Q1. What is a “Tax Year” and why has the terminology changed?

Short answer: It replaced Financial Year and Assessment Year under the Income-tax Act, 2025.

A Tax Year means a 12-month period from 1 April to 31 March the following year, replacing the earlier FY/AY framework. TY 2026-27 therefore runs 1 April 2026 to 31 March 2027. Older documents referring to AY 2027-28 for the same period are using the superseded terminology. EZTax

Q2. Which filings does a foreign-owned subsidiary have that a domestic company does not?

Short answer: The FEMA and cross-border set.

FC-GPR on share allotment to a non-resident, FC-TRS on transfers between residents and non-residents, the annual FLA return to the RBI, ECB-2 monthly returns where there is a shareholder loan or external borrowing, Form 3CEB for transfer pricing, Form 27Q for non-resident withholding, and Form 145/146 before each outward remittance. None of these exist for a purely domestic company, which is exactly why they get missed.

Q3. When is the FLA return due?

Short answer: 15 July every year — including years with no transaction.

It is filed with the RBI by every Indian company that has received FDI or made overseas investment in any previous year. There is no exemption for a dormant year. Where the audit is not complete, the return is filed on unaudited figures and revised later.

Q4. How long do I have to file FC-GPR after issuing shares to my parent?

Short answer: 30 days from allotment.

The period runs from the date of allotment, not the date funds were received and not the date of the board resolution. The supporting documents — FIRC and KYC from the AD bank, valuation certificate, CS certificate — take time to assemble, so begin on the allotment date.

Q5. What are the penalties for late AOC-4 and MGT-7?

Short answer: ₹100 per day, with no upper limit.

Both attract ₹100 per day in additional fees with no cap — AOC-4 is due within 30 days of the AGM and MGT-7 within 60 days. Because there is no ceiling, a filing delayed while the group decides who signs becomes an open-ended liability rather than a fixed penalty. LegalsuvidhaRegisterKaro

Q6. When is the income tax return due for a company with transfer pricing transactions?

Short answer: 30 November, with Form 3CEB by 31 October.

Form 3CEB is due 31 October and the return for entities subject to transfer pricing audit is due 30 November. Ordinary audit cases file by 31 October. The additional month is not spare capacity — the benchmarking study behind the certificate needs to start months earlier. Legalsuvidha + 2

Q7. Does my subsidiary need to file Form 3CEB if it only pays a management fee to the parent?

Short answer: Yes. A management fee is an international transaction with an associated enterprise.

The scope is much wider than most groups assume. Management fees, royalty, cost recharges, intercompany loans and guarantees, and purchases or sales of goods with group entities all count. Scoping Form 3CEB too narrowly — typically by omitting recharges and guarantees — is a common and avoidable exposure.

Q8. Is DIR-3 KYC still due on 30 September every year?

Short answer: No. The regime changed on 31 March 2026 — verify your own date.

Many calendars published for FY 2026-27 still state 30 September annually. With effect from 31 March 2026, Director KYC moved to a triennial cycle under amended Rule 12A, and separately any change in a director’s address, email or mobile must be intimated within 30 days. Commentary on the transition has been inconsistent, so check each director’s DIN status on the MCA portal and confirm the due year with your Company Secretary. RegisterKaro

Q9. We took a loan from our parent company. What does that trigger?

Short answer: Three separate regimes — ECB, DPT-3 and TDS.

The loan is likely an external commercial borrowing, requiring a Loan Registration Number and monthly ECB-2 returns through your AD bank. The outstanding amount also reports in DPT-3 by 30 June. And interest paid to the parent attracts withholding, reported in Form 27Q with a Form 145 filing before each remittance. Three regimes, one transaction, and typically three different advisors — none of whom assumes it is theirs. RegisterKaro

Q10. When are GSTR-9 and GSTR-9C due?

Short answer: 31 December.

The annual GSTR-9 return is due by 31 December for businesses with turnover above ₹2 crore, and GSTR-9C for turnover above ₹5 crore. Reconciliation should begin in October rather than December — intercompany entries are precisely the items that fail reconciliation, and they take longest to resolve across time zones. RegisterKaroLegalsuvidha

Q11. Do we pay GST on the management fee we pay our parent?

Short answer: Yes — under reverse charge.

Import of services from an associated enterprise abroad attracts GST on a reverse charge basis in the hands of the Indian recipient. This is separate from, and additional to, the income tax withholding on the same payment. It is one of the most commonly missed items in the first year of a subsidiary’s operation, because no invoice with Indian GST on it ever arrives.

Q12. What is the single most missed compliance by foreign-owned Indian companies?

Short answer: The FLA return.

It is not a tax filing, not an MCA filing, and sits with the RBI. Your tax advisor does not file it, your company secretary does not file it, and your auditor does not remind you. Assign it to a named person today, with 15 July as a recurring calendar entry and a backup owner.