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Accounting & Bookkeeping in India for Chinese Companies

Navigate Press Note 3 compliance, India-China DTAA reporting, and Indian Accounting Standards to maintain accurate financial records for your Indian subsidiary.

10 min readBy Manu RaoUpdated March 2026

DTAA Rate

10% on fees for technical services, 10% on royalties, 10% on interest under India-China DTAA

Bilateral Agreement

India-China DTAA since 1994 (amended 2018 protocol); Press Note 3 restrictions relaxed March 2026

Doc Authentication

Embassy attestation

Timeline

2-4 weeks for initial setup; ongoing monthly engagement

Accounting & Bookkeeping for Chinese Companies in India

China remains India's second-largest trading partner, with bilateral trade reaching approximately USD 127.7 billion in FY 2024-25. Despite the complex geopolitical landscape following the Galwan Valley standoff in 2020, over 100 Chinese companies continue to operate in India across sectors including electronics, telecommunications, renewable energy, and automotive manufacturing. With India relaxing FDI norms for countries sharing a land border in March 2026, more Chinese enterprises are expected to establish or expand their Indian presence.

For any Chinese company operating an Indian subsidiary, accounting and bookkeeping is not merely an operational function — it is a critical compliance requirement that intersects with FEMA reporting, transfer pricing documentation, Press Note 3 monitoring, and the India-China Double Taxation Avoidance Agreement. Indian accounting standards require meticulous record-keeping in a specific format, and errors can trigger regulatory scrutiny that is particularly intense for Chinese-owned entities given the heightened compliance oversight under PN3.

Engaging a qualified Indian accounting firm from the outset ensures that your subsidiary's books are maintained in accordance with the Companies Act, 2013, the Income Tax Act, 1961, and applicable Indian Accounting Standards (Ind AS or Indian GAAP), while also meeting your parent company's reporting requirements under Chinese Accounting Standards (CAS).

How China's DTAA Affects Accounting & Bookkeeping

The India-China DTAA, signed on 18 July 1994 and amended through the 2018 protocol, directly impacts how your Indian subsidiary accounts for cross-border transactions with the Chinese parent company.

Withholding Tax Rates Under the Treaty

For accounting purposes, your bookkeeper must correctly apply DTAA withholding rates on all payments to the Chinese parent:

  • Fees for Technical Services (FTS): 10% under DTAA versus 20% plus surcharge and cess under domestic Indian law. Accounting and bookkeeping services provided by the Chinese parent to the Indian subsidiary may qualify as FTS if they involve technical or consultancy elements.
  • Royalties: 10% under DTAA versus 20% domestically. Technology licensing fees from the parent company must be booked at the correct withholding rate.
  • Interest: 10% on inter-company loans. Your books must reflect the correct TDS deduction and deposit timelines.
  • Dividends: 10% under DTAA. Dividend distribution accounting must comply with both Indian and DTAA provisions.

Transfer Pricing Documentation

Chinese subsidiaries in India face heightened transfer pricing scrutiny. Your accounting system must capture every related-party transaction — management fees, shared service charges, IP royalties, inter-company loans — with sufficient documentation to justify arm's length pricing. The bookkeeping function must maintain transaction-level records that support the annual transfer pricing study and Form 3CEB filing by your Chartered Accountant.

Permanent Establishment Risk

Your accounting records must clearly demonstrate that the Indian entity operates as an independent subsidiary rather than a dependent agent of the Chinese parent. The 2018 DTAA protocol aligned Permanent Establishment definitions with OECD standards, making it critical to maintain separate books, independent decision-making documentation, and clear functional delineation.

Document Requirements from China

Setting up an accounting function for a Chinese-owned Indian subsidiary requires specific documentation, particularly given that India and China follow the embassy attestation route rather than apostille. India officially objected to China's accession to the Hague Apostille Convention in September 2023, so all documents must pass through a four-step legalization chain.

Documents Needed for Accounting Setup

  • Board Resolution from the Chinese parent authorizing the Indian subsidiary's accounting policies, chart of accounts, and appointment of auditors — notarized by a Chinese Notary Public, authenticated by China's Ministry of Foreign Affairs, and attested by the Indian Embassy in Beijing or Consulate in Shanghai/Guangzhou.
  • Inter-company agreements covering shared services, management fees, royalties, and loans — each agreement must be properly authenticated for transfer pricing compliance.
  • Parent company financial statements under CAS for consolidation reference.
  • Power of Attorney for authorized signatories who will approve financial statements and sign tax returns.
  • Bank mandates and authorization letters for operating the subsidiary's Indian bank accounts.

Embassy Attestation Timeline

Since apostille is not available between India and China, each document set takes approximately 3-4 weeks to complete the four-step chain: Chinese notarization, MOFA authentication, Indian Embassy attestation, and final verification. Companies should prepare all accounting-related agreements well in advance of the subsidiary's operational start date.

Step-by-Step Accounting & Bookkeeping Process

Once your Chinese company's Indian subsidiary is incorporated, the accounting function must be established systematically to meet Indian regulatory requirements.

Step 1: Chart of Accounts Setup

Design an Indian chart of accounts that aligns with both Indian Accounting Standards and your Chinese parent's CAS reporting requirements. This dual-purpose structure ensures efficient monthly reporting to the parent while maintaining Indian compliance. Key considerations include mapping Chinese account codes to Indian equivalents and establishing currency conversion protocols for CNY-INR transactions.

Step 2: Accounting Software Selection

Select an Indian accounting software that supports GST compliance, TDS calculations, and statutory reporting. Popular choices include Tally Prime, Zoho Books, or SAP Business One (if the Chinese parent uses SAP). The software must support e-invoicing under GST for businesses exceeding the applicable turnover threshold.

Step 3: GST Registration and Compliance Setup

Configure the accounting system for GST compliance — GSTR-1 (outward supplies by the 11th of each month), GSTR-3B (summary return by the 20th), and annual GSTR-9. For Chinese companies importing goods or services from the parent, reverse charge mechanism entries must be correctly recorded.

Step 4: TDS Compliance Framework

Set up automated TDS deduction and deposit workflows. Your bookkeeper must deduct TDS on payments for professional services (Section 194J), rent (Section 194-I), contractor payments (Section 194C), and cross-border payments to the Chinese parent at DTAA rates. TDS returns (Form 24Q, 26Q, 27Q) must be filed quarterly.

Step 5: FEMA and RBI Reporting Integration

For Chinese-owned subsidiaries, FEMA compliance is particularly rigorous. Your accounting system must track all foreign currency transactions, capital account movements, and prepare data for the annual Foreign Liabilities and Assets (FLA) return filed with the RBI by 15 July each year. FC-GPR filings for share allotments must be completed within 30 days.

Step 6: Monthly Closing and Reporting

Establish a monthly closing calendar: reconcile all bank accounts, complete inter-company transaction matching with the Chinese parent, prepare management reports in both INR and CNY, and generate compliance checklists for GST, TDS, and advance tax obligations.

Timeline and Costs

Accounting and bookkeeping for Chinese subsidiaries involves both one-time setup costs and ongoing monthly engagement fees.

Timeline Breakdown

ActivityDuration
Chart of accounts design and software setup1-2 weeks
GST and TDS configuration1 week
Opening balance migration (if applicable)1-2 weeks
First month-end close process2-3 weeks (subsequent months: 5-7 business days)
Annual financial statements preparation3-4 weeks

Cost Breakdown

ComponentEstimated Cost (Annual)
Monthly bookkeeping (up to 200 transactions)INR 15,000 - 30,000 per month
Monthly bookkeeping (200-500 transactions)INR 30,000 - 60,000 per month
GST return filing (monthly)INR 5,000 - 15,000 per month
TDS return filing (quarterly)INR 3,000 - 8,000 per quarter
Annual financial statements and audit supportINR 50,000 - 2,00,000
Transfer pricing documentation supportINR 75,000 - 3,00,000
FEMA/RBI reporting supportINR 25,000 - 75,000

Note: Costs vary based on transaction volume, complexity of inter-company arrangements, and whether the subsidiary has manufacturing operations versus a services business. Chinese subsidiaries typically have higher bookkeeping costs due to additional PN3-related compliance and transfer pricing documentation requirements.

Common Challenges for Chinese Companies

1. Press Note 3 Compliance Monitoring

Even with the March 2026 relaxation of PN3 norms, Chinese-owned subsidiaries face ongoing compliance monitoring. Your accounting records must demonstrate adherence to the conditions specified in the government approval — investment amounts, sector restrictions, and employment commitments. Any deviation from the approved FDI structure must be reported, and your bookkeeper must flag transactions that could trigger additional regulatory review.

2. Currency Conversion Complexities

The Chinese Yuan (CNY) has restricted convertibility, which creates unique challenges for capital account transactions. Your accounting system must handle INR-CNY conversions using RBI reference rates, track exchange gains and losses accurately, and ensure compliance with FEMA pricing guidelines for inter-company transactions. The restricted nature of CNY outward remittance through China's State Administration of Foreign Exchange (SAFE) adds an additional documentation layer.

3. Dual Reporting Standards

Chinese parent companies follow Chinese Accounting Standards (CAS), which have converged substantially with IFRS but retain key differences — particularly in revenue recognition, government grant accounting, and consolidation standards. Your Indian subsidiary must maintain books under Indian GAAP or Ind AS, while providing monthly or quarterly reporting packages in CAS format for consolidation by the Chinese parent. This dual-standard reporting requirement increases bookkeeping complexity and cost.

4. Banking and Payment Reconciliation

Some Indian banks exercise additional caution with Chinese-owned entities, resulting in slower payment processing and additional documentation requirements for cross-border remittances. Your bookkeeper must maintain detailed reconciliation records for all international transfers, particularly management fee payments and royalty remittances, which often face enhanced scrutiny from both Indian and Chinese banking regulators.

5. Enhanced Audit Scrutiny

Indian tax authorities are known to subject Chinese-owned subsidiaries to more frequent tax audits and transfer pricing assessments. Your accounting records must be audit-ready at all times, with complete supporting documentation for every related-party transaction, expense claim, and cross-border payment.

Why Choose BeaconFiling

BeaconFiling provides specialized accounting and bookkeeping services tailored for Chinese companies operating in India. Our team understands the unique compliance environment that Chinese subsidiaries navigate — from Press Note 3 reporting obligations to FEMA documentation, transfer pricing record-keeping, and dual-standard financial reporting.

We assign a dedicated accountant who maintains your books in accordance with Indian Accounting Standards while preparing consolidated reporting packages compatible with your Chinese parent's CAS requirements. Our proactive compliance calendar ensures that no GST, TDS, advance tax, or FEMA deadline is missed, and our transfer pricing support team maintains transaction-level documentation throughout the year rather than scrambling at year-end.

Explore our accounting and bookkeeping services or contact us for a free consultation tailored to your Chinese company's India operations.

Frequently Asked Questions

Does my Chinese subsidiary in India need to follow Indian Accounting Standards or Chinese Accounting Standards?

Your Indian subsidiary must maintain its statutory books of accounts in accordance with Indian Accounting Standards — either Indian GAAP or Ind AS, depending on your subsidiary's net worth and turnover thresholds. However, you will also need to prepare reporting packages in CAS format for consolidation by your Chinese parent company. BeaconFiling handles both requirements through a dual-mapped chart of accounts.

How does Press Note 3 affect my accounting and bookkeeping requirements?

Press Note 3 adds compliance monitoring obligations to your accounting function. Your books must track adherence to the conditions specified in your government approval — investment deployment timelines, sector restrictions, and employment commitments. With the March 2026 relaxation, some Chinese companies may qualify for automatic route investment, but the accounting team must still maintain records demonstrating compliance with applicable conditions.

What are the FEMA reporting requirements for Chinese-owned subsidiaries?

Key FEMA reports include FC-GPR (within 30 days of share allotment), the annual Foreign Liabilities and Assets (FLA) return by 15 July, and Single Master Form filings for ongoing transactions. Your bookkeeper must maintain real-time tracking of all foreign currency inflows and outflows to ensure timely and accurate FEMA reporting through the RBI's FIRMS portal.

Can I use Chinese accounting software for my Indian subsidiary?

Your Indian subsidiary's primary accounting software must comply with Indian GST e-invoicing requirements, TDS computation rules, and statutory reporting formats. Chinese software like Kingdee or Yonyou is not configured for Indian statutory compliance. We recommend Indian platforms such as Tally Prime or Zoho Books as the primary system, with data exports formatted for import into your Chinese parent's ERP system.

How are inter-company transactions between my Chinese parent and Indian subsidiary taxed?

Inter-company transactions — management fees, royalties, technical service charges, interest on loans — are subject to withholding tax at DTAA rates (10% under the India-China DTAA) and must comply with transfer pricing regulations. Your accounting system must record each transaction with sufficient documentation to justify arm's length pricing, and TDS must be deducted and deposited before the 7th of the following month.

What is the penalty for not maintaining proper books of accounts in India?

Under Section 128 of the Companies Act, 2013, failure to maintain proper books of accounts can result in imprisonment of up to one year and a fine ranging from INR 50,000 to INR 5,00,000 for every officer in default. Additionally, non-compliance with GST record-keeping requirements can attract penalties under the CGST Act, and transfer pricing documentation failures can result in penalties of 2% of the transaction value under Section 271AA of the Income Tax Act.

Do I need a separate audit for my Indian subsidiary even if the Chinese parent is audited?

Yes. Under the Companies Act, 2013, every Indian company — including wholly owned subsidiaries of foreign companies — must appoint an independent statutory auditor and undergo an annual audit. This is separate from any audit conducted by the Chinese parent's auditors. If your subsidiary's turnover exceeds INR 1 crore (INR 10 crore for businesses opting for presumptive taxation), a tax audit under Section 44AB of the Income Tax Act is also mandatory.

Frequently Asked Questions

Frequently Asked Questions

Your Indian subsidiary must maintain its statutory books of accounts in accordance with Indian Accounting Standards — either Indian GAAP or Ind AS, depending on your subsidiary's net worth and turnover thresholds. However, you will also need to prepare reporting packages in CAS format for consolidation by your Chinese parent company.
Press Note 3 adds compliance monitoring obligations to your accounting function. Your books must track adherence to the conditions specified in your government approval — investment deployment timelines, sector restrictions, and employment commitments. With the March 2026 relaxation, some Chinese companies may qualify for automatic route investment, but accounting records must still demonstrate compliance.
Key FEMA reports include FC-GPR (within 30 days of share allotment), the annual Foreign Liabilities and Assets (FLA) return by 15 July, and Single Master Form filings for ongoing transactions. Your bookkeeper must maintain real-time tracking of all foreign currency inflows and outflows for timely and accurate FEMA reporting.
Your Indian subsidiary's primary accounting software must comply with Indian GST e-invoicing requirements, TDS computation rules, and statutory reporting formats. Chinese software like Kingdee or Yonyou is not configured for Indian statutory compliance. We recommend Indian platforms such as Tally Prime or Zoho Books as the primary system.
Inter-company transactions — management fees, royalties, technical service charges, interest on loans — are subject to withholding tax at DTAA rates (10% under the India-China DTAA) and must comply with transfer pricing regulations. TDS must be deducted and deposited before the 7th of the following month.
Under Section 128 of the Companies Act, 2013, failure to maintain proper books of accounts can result in imprisonment of up to one year and a fine ranging from INR 50,000 to INR 5,00,000 for every officer in default. Additionally, transfer pricing documentation failures can result in penalties of 2% of the transaction value under Section 271AA.
Yes. Under the Companies Act, 2013, every Indian company — including wholly owned subsidiaries of foreign companies — must appoint an independent statutory auditor and undergo an annual audit. This is separate from any audit conducted by the Chinese parent's auditors. A tax audit under Section 44AB may also be mandatory depending on turnover.

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