India Subsidiary First-Year Compliance Calendar

An estimate, not a determination. Dates are computed from the statutory periods and may move if the government extends due dates. C S Rushil & Co. confirms the calendar for your company before anything is filed.

How do I use this compliance calendar?

The calendar needs only two dates and the parent's country. Follow the steps below; you can change any input and rebuild the calendar as plans firm up.

1. Choose the parent's country. This sets the note on how documents signed abroad are legalised before they are used in India.
2. Enter the date of incorporation. Use the date on the certificate of incorporation issued by the Registrar of Companies.
3. Check the date of first share allotment. It defaults to 30 days after incorporation. Change it to the date the Board allots, or plans to allot, shares to the foreign parent against the money received.
4. Leave the financial year end at 31 March. Indian companies follow an April to March year, so this input is fixed.
5. Read the calendar. The table lists each filing in date order, with the statutory period behind each date, followed by the document note for the parent's country.
6. Send it for review. The WhatsApp button sends a short summary of your dates and the first deadlines, so a CA can check the calendar against your facts.

Which filings fall due in a subsidiary's first year?

A foreign-owned company has the same company law filings as any Indian company, plus reporting to the Reserve Bank of India on the foreign investment and, where it deals with its group, transfer pricing documentation. The table summarises the periods the calendar applies.

Why do the first 30 days after incorporation matter so much?

Two things happen early. The Board appoints the company's first auditor within 30 days of incorporation, and the parent remits the subscription money so that shares can be allotted. Once shares are allotted to the foreign investor, Form FC-GPR is due on the RBI FIRMS portal within 30 days of the allotment. FC-GPR reports the issue of shares against foreign investment, and it is supported by the bank's confirmation of the inward remittance, a valuation and a company secretary's certificate, so the paperwork is best prepared before the allotment rather than after it.

An FC-GPR can be missed when an allotment is made in a board meeting and nobody links it to the RBI deadline. Putting the allotment date into the calendar shows the FC-GPR date straight away. Our FEMA and RBI compliance service covers FC-GPR, the FLA return and the other foreign investment reporting.

What is INC-20A and why does it have a 180-day limit?

Form INC-20A is the company's declaration to the Registrar of Companies that every subscriber has paid for the shares they agreed to take and that the company has commenced business. It must be filed within 180 days of incorporation. For a subsidiary, that means the parent's subscription money has to arrive in the company's Indian bank account in time, which depends on the parent's internal approvals and its bank. The calendar shows the 180th day so the treasury team abroad has a firm date to work towards.

How are the RBI FLA return and transfer pricing dates worked out?

The Foreign Liabilities and Assets return is an annual RBI return for Indian companies that have received foreign direct investment. It is due by 15 July each year. The calendar shows the first one as 15 July after the first 31 March following the allotment to the foreign investor, and you should expect it every year after that.

Where the subsidiary has international transactions with its parent or other group companies, such as service fees, cost recharges, royalties or loans, an accountant's report on transfer pricing is required. The calendar shows it as due by 31 October after the end of the first tax year, with the income tax return by 30 November. The report has been Form 3CEB; under the Income-tax Act, 2025, it is Form 48 from tax year 2026-27 onward, and the calendar labels it accordingly. Our transfer pricing audit service covers the benchmarking and the report.

When is the first AGM, and what follows it?

A company holds its first annual general meeting within nine months of the end of its first financial year. For a year ending 31 March, that is by 31 December. After the AGM, the financial statements are filed with the Registrar in Form AOC-4 within 30 days, and the annual return in Form MGT-7 within 60 days. The calendar assumes the AGM is held on its last permitted day, so the AOC-4 and MGT-7 dates it shows are the latest dates; an earlier AGM brings both forward.

If the company is incorporated between 1 January and 31 March, its first financial year under the Companies Act may run to 31 March of the following year, while the first tax year still ends on the 31 March just after incorporation. The calendar reflects that split and says so in the result. Ask us to confirm which year end your company is using before you plan the audit.

What documents does the parent company need from abroad?

The parent signs board resolutions, subscription documents and authorisations, and its directors may sign declarations as well. Documents signed outside India are legalised before they are used here, and the route depends on the country.

Country guides: India subsidiary for US companies, India subsidiary for UK companies, India subsidiary for UAE companies and India subsidiary for Singapore companies. If you have not yet incorporated, start with company registration in India for foreigners, and use our company registration government fee calculator for the statutory charges.

How should a foreign parent plan around these dates?

Most first-year delays start outside India. Board resolutions have to be signed, legalised and couriered, the subscription money has to clear the parent's treasury approvals, and someone in group finance has to collect the bank's remittance details for the RBI filing. Working backwards from the calendar helps: if FC-GPR is due 30 days after allotment, the documents for it should be ready on the day of allotment, and the remittance should be in the Indian bank account well before INC-20A falls due.

It also helps to decide early who in the group owns each filing. The Indian directors sign most of the forms, but the information comes from the parent: shareholding details, valuation inputs, intercompany agreements and the figures for transfer pricing. A shared calendar with named owners and internal target dates a week or two before each statutory date keeps the first year orderly, and the same calendar carries into the second year with the FLA return, the audit and the annual filings recurring.

Is this calendar the full list of compliance for the year?

No. It covers the main first-year company law, RBI and transfer pricing deadlines. A subsidiary also has recurring work that the calendar does not list: monthly and quarterly GST and TDS returns, payroll, board meetings, statutory registers and the audit itself. Many foreign parents prefer one team to hold the whole calendar and report to group finance each month. Our India subsidiary compliance and CFO retainer does that, and you can start with a 15-minute consultation.

Is the result of this calendar final?

No. The dates are computed from the statutory periods and may move if the government extends due dates or if the actual dates of allotment and the AGM differ from those assumed. C S Rushil & Co. advises on Indian law only; tax and company law in the parent's country are for its own advisers. Clients abroad are served online.