Tax Director's Annual Calendar for India Compliance

The Compliance Landscape for Foreign-Owned Indian Entities

Managing corporate tax compliance for an Indian subsidiary or branch office from a regional or global headquarters requires tracking deadlines across six distinct regulatory regimes: income tax, GST, TDS/TCS, MCA/ROC, FEMA/RBI, and transfer pricing. A single missed deadline can trigger penalties ranging from INR 200 per day to three times the transaction value under FEMA.

This calendar follows India's financial year (1 April to 31 March), which governs most tax and compliance deadlines. GST deadlines run monthly. ROC deadlines are event-driven around the Annual General Meeting. FEMA deadlines are fixed calendar dates.

For tax directors at foreign companies with wholly owned subsidiaries, branch offices, or liaison offices in India, this calendar should be your baseline planning document for FY 2026-27.

April: New Financial Year Opens

Monthly Recurring (Every Month)

April-Specific Deadlines

• 1 April — New financial year begins. Update TDS rates per latest Finance Act. Verify any changes in GST rates or compliance requirements.
• 7 April — TDS deposit for March deductions. Note: TDS deposited in March can use the extended deadline of 30 April for government deductors only.
• 14 April — Issue Form 16A (TDS certificates) for Q3 (October-December) to deductees.
• 30 April — TDS deposit for March (extended deadline). File TCS return for Q4 (January-March) in Form 27EQ.

May: TDS Returns and First GST Annual Preparation

• 15 May — Issue Form 16 (salary TDS certificate) to employees for the previous financial year. This is the employee's primary document for filing personal income tax returns.
• 31 May — File TDS returns for Q4 (January-March): Form 24Q (salaries), Form 26Q (non-salary Indian payments), Form 27Q (payments to non-residents). This is the most critical TDS return deadline as it covers year-end adjustments. Late filing attracts INR 200/day penalty.

June: Advance Tax First Installment

• 7 June — Monthly TDS deposit for May deductions.
• 14 June — Issue Form 16A (TDS certificates) for Q4 (January-March).
• 15 June — First installment of advance tax — Pay at least 15% of estimated annual tax liability. Failure to pay attracts interest under Section 234C at 1% per month on the shortfall amount.
• 30 June — File Form DPT-3 (return of deposits) with ROC. All companies with outstanding loans or deposits from directors must file. Penalty: INR 50,000 to INR 25 lakh.

Strategic note: June is the month to finalize your full-year tax estimate. Work with your tax advisory team to project income, deductions, MAT/AMT liability, and any DTAA benefits that will apply.

July: FEMA and Income Tax Filing Season Opens

• 15 July — FLA Return filing deadline — File the Annual Return on Foreign Liabilities and Assets with the RBI through the FLAIR portal. Mandatory for all Indian entities with FDI or overseas investments. Penalty for non-filing: up to INR 2 lakh plus INR 5,000/day for continuing default. The RBI may extend this deadline — in 2025, it was extended to 31 July.
• 31 July — File TDS returns for Q1 (April-June): Forms 24Q, 26Q, 27Q. Issue Form 16A for Q1 to deductees within 15 days of the TDS return due date.
• 31 July — Income Tax Return (ITR) due date for non-audit cases (individuals, companies not requiring audit). Most foreign-owned companies require audit, so this does not apply to them — but it applies to the resident director personally.

August-September: Audit Season

August

• No major statutory deadlines — but this is the critical preparation month. Finalize statutory audit of books. Coordinate with auditors on audit adjustments, related-party disclosures, and transfer pricing documentation.

September

• 15 September — Second installment of advance tax — Cumulative payment should reach 45% of estimated annual liability. Interest under Section 234C applies on any shortfall.
• 30 September — Annual General Meeting (AGM) — Must be held within 6 months of the financial year end. Foreign directors can attend via video conferencing under the Companies Act. The AGM approves financial statements, appoints/reappoints auditors, and declares dividends.
• 30 September — Tax Audit Report due (under Section 44AB) for companies with turnover exceeding INR 10 crore (INR 5 crore if cash receipts/payments exceed 5% of total). File with the Income Tax Department.
• 30 September — Revised FLA Return — If the original FLA filing was based on unaudited accounts, submit a revised return based on audited financials through the FLAIR portal.

Strategic note: September is the most deadline-dense month of the year. Begin audit preparation in July. Pre-close books by 15 August. Have the AGM notice issued 21 days before the meeting date.

October: ITR Filing and ROC Returns

• 15 October — Issue Form 16A for Q2 (July-September).
• 29 October — File Form AOC-4 with ROC — Financial statements (balance sheet, P&L, notes) filed within 30 days of the AGM. Penalty: INR 100/day delay with no cap. Director disqualification risk if missed for 3 consecutive years.
• 31 October — Income Tax Return (ITR) due date for companies requiring audit (which includes virtually all foreign-owned subsidiaries). File ITR-6 for companies. Late filing attracts penalty up to INR 5,000 under Section 234F.
• 31 October — Form 3CEB — Transfer Pricing Audit Report due. Mandatory for companies with international transactions or specified domestic transactions exceeding INR 1 crore. The CA certifies arm's length pricing. Penalty for non-filing: INR 1 lakh under Section 271BA.
• 31 October — File TDS returns for Q2 (July-September).

November: Transfer Pricing and Annual Return

• 28 November — File Form MGT-7/MGT-7A with ROC — Annual return filed within 60 days of the AGM. Includes details of directors, shareholders, share capital changes, and meetings held. Penalty: INR 100/day delay with no cap.
• 30 November — ITR due date for transfer pricing cases — Companies required to file Form 3CEB get an extended deadline for ITR filing. This applies to most foreign-owned subsidiaries with related-party international transactions.

Strategic note: If your subsidiary has transfer pricing exposure, the October-November window is critically compressed. Begin TP documentation in Q2 (July-September) and have draft Form 3CEB ready by mid-October.

December: Advance Tax and Year-End Planning

• 15 December — Third installment of advance tax — Cumulative payment should reach 75% of estimated annual liability. This is typically the largest single installment as full-year income becomes clearer. Interest at 1% per month under Section 234C applies on any shortfall.
• 31 December — Last date for filing belated or revised ITR for the previous assessment year. If you discovered errors in the ITR filed in October/November, this is the final correction window.

January-February: Q3 TDS and Pre-Close Activities

January

• 15 January — Issue Form 16A for Q3 (October-December) — note this is an accelerated timeline per recent amendments.
• 31 January — File TDS returns for Q3 (October-December): Forms 24Q, 26Q, 27Q.

February

• Union Budget — Typically presented on 1 February. Monitor for changes to corporate tax rates, withholding tax provisions, transfer pricing rules, and GST reforms. Brief your global tax team within 48 hours of the Budget speech.
• Mid-February — Begin financial year-end pre-close. Reconcile inter-company balances with the parent entity. Confirm transfer pricing adjustments for year-end. Accrue all known liabilities.

March: Year-End Close and Fourth Advance Tax

• 15 March — Fourth and final installment of advance tax — Pay 100% of estimated annual tax liability. Any shortfall from this date attracts interest under Section 234B (for total shortfall) and 234C (for installment shortfall) at 1% per month each.
• 31 March — Financial year ends. Ensure all books are current, all TDS has been deposited, all GST returns filed, and inter-company invoices are raised for the full year.

Strategic note: March is the most operationally intense month. Key activities include:

• Physical stock verification (if applicable)
• Confirmation of debtors and creditors balances
• Final transfer pricing adjustments to inter-company accounts
• Advance tax calculation with actual figures (not estimates)
• Year-end provision review with auditors

Annual Filing Summary Table

GST Annual Return and Reconciliation

Beyond monthly GSTR-3B and GSTR-1 filings, foreign-owned Indian subsidiaries must file the GST Annual Return (GSTR-9) by 31 December each year. For companies with turnover exceeding INR 5 crore, GSTR-9C (reconciliation statement between GSTR-9 and audited financial statements) is also mandatory, self-certified by the taxpayer (no longer requiring CA certification since FY 2020-21).

Key reconciliation items to prepare:

• Reconcile outward supplies reported in GSTR-1 with revenue in audited books
• Match input tax credit claimed in GSTR-3B against GSTR-2B auto-populated data
• Identify and reverse blocked credits under Section 17(5) — entertainment, food, club memberships
• Reconcile inter-state and intra-state supply classification
• Verify HSN-wise summary matches actual invoicing

Late GSTR-9 filing attracts a penalty of INR 200 per day (INR 100 CGST + INR 100 SGST), capped at 0.5% of annual turnover. For a subsidiary with INR 50 crore turnover, this cap is INR 25 lakh — a material amount.

FEMA Compliance Beyond FLA Return

Tax directors at foreign-owned entities must track several FEMA compliance deadlines beyond the annual FLA return:

• FC-GPR — Filed within 30 days of any share allotment to foreign investors. Event-triggered, not calendar-based.
• FC-TRS — Filed within 60 days of transfer of shares from a resident to a non-resident (or vice versa).
• ECB reporting — Monthly ECB-2 return filed within 7 working days of the end of each month for outstanding external commercial borrowings.
• Annual Performance Report (APR) — Due by 31 December for Indian companies with overseas direct investments (ODI). Filed through the RBI's OID portal.
• Form ODI Part II — Event-based filing within 30 days of any disinvestment or other material change in overseas investment.

FEMA penalties are the most severe in India's compliance landscape. Under Section 13 of FEMA, penalties can be up to three times the amount involved in the contravention, or INR 2 lakh where the amount is not quantifiable — plus INR 5,000 per day of continuing default.

Director Compliance Obligations

Foreign directors serving on Indian subsidiary boards have personal compliance obligations that the tax director should track:

• DIR-3 KYC — Annual KYC filing by every director by 30 September. Non-filing results in DIN deactivation, which blocks all MCA filings.
• MBP-1 — Disclosure of interest by directors at the first board meeting of each financial year (April meeting).
• Personal ITR filing — Indian resident directors must file personal income tax returns by 31 July. Foreign directors receiving director fees from the Indian entity must obtain a PAN and file returns in India.
• Form DPT-3 — While a company-level filing, directors are personally liable if the company fails to file this return of deposits by 30 June.

Strategic Planning Framework for Tax Directors

Quarterly Cadence for Global Reporting

Most multinational companies operate on quarterly reporting cycles. Align your India compliance calendar with the global reporting cadence:

• Q1 (April-June) — File FY-end TDS returns, first advance tax, FLA return. Provide global tax team with effective tax rate projections for the new year.
• Q2 (July-September) — Audit season. AGM. Tax audit. Begin transfer pricing documentation. This is the most resource-intensive quarter.
• Q3 (October-December) — ITR filing, TP audit, ROC annual returns. Year-end planning begins. Advance tax third installment.
• Q4 (January-March) — Budget monitoring, year-end close, final advance tax. Provide global tax team with year-end tax provision numbers.

Resource Planning

For a foreign-owned subsidiary with turnover between INR 10-100 crore, plan for:

• Statutory auditor fees: INR 5-15 lakh per year
• Transfer pricing documentation and Form 3CEB: INR 3-8 lakh per year
• Tax return preparation (ITR-6): INR 1-3 lakh per year
• Annual compliance management (ROC, FEMA, GST): INR 3-8 lakh per year
• Total external compliance cost: INR 12-34 lakh per year (approximately USD 14,000-40,000)

Technology and Automation Recommendations

Managing 100+ annual compliance deadlines manually is a recipe for missed filings. Tax directors should evaluate the following technology solutions:

• Compliance management platforms — Solutions like Diligent, LegalRaasta, or ComplianceEase provide automated calendar tracking with email and SMS alerts for approaching deadlines. Most Indian CA firms now offer their own compliance portals as part of retainer services.
• GST filing software — For companies with high transaction volumes, tools like ClearTax, TallyPrime with GST module, or Masters India automate GSTR-1 preparation from sales data and reconcile GSTR-2B for input tax credit matching.
• TDS automation — Integrating TDS computation and challan generation with payroll and accounts payable systems eliminates the most common source of penalties. Solutions like Saral TDS or ClearTax TDS automate Form 24Q/26Q/27Q preparation.
• Inter-company transaction tracking — For transfer pricing documentation, maintaining a real-time log of all inter-company transactions (services, royalties, management fees, cost allocations) through ERP modules or dedicated TP software significantly reduces the year-end documentation burden.

A mid-size subsidiary spending INR 3-5 lakh per year on compliance technology can save multiples of that amount in avoided penalties, reduced professional fees for last-minute filings, and freed-up internal resources.

Key Takeaways

• September and October are the most deadline-dense months — AGM, tax audit, ITR filing, TP audit, and ROC filings all converge. Begin preparation in July.
• TDS compliance is the highest-frequency obligation — monthly deposits (7th) and quarterly returns. A single late deposit attracts 1.5% per month interest, compounded.
• Advance tax installments (15 June, September, December, March) must be calculated accurately. Interest at 1% per month under Sections 234B and 234C adds up rapidly on large tax liabilities.
• The FLA Return to RBI (15 July) is often overlooked by companies focused on income tax. Non-filing risks FEMA penalties of up to INR 2 lakh plus INR 5,000 per day of continuing default.
• Budget your external compliance costs at INR 12-34 lakh per year for a mid-size subsidiary. Factor this into your India entity's operating budget from day one.