Annual Compliance Calendar for Indian Subsidiaries

Running an Indian subsidiary of a foreign company means navigating a complex web of regulatory filings across multiple authorities — the Ministry of Corporate Affairs (MCA), Income Tax Department, GST Network, Reserve Bank of India (RBI), EPFO, ESIC, and state-level bodies. Missing a deadline can mean penalties, prosecution of directors, or loss of compliance status. This month-by-month calendar covers every major obligation.

Recurring Monthly Obligations

Before diving into the month-by-month calendar, note these obligations that recur every month:

April (Start of Financial Year)

• April 14 — GSTR-1 for March (year-end month, ensure all B2B invoices are captured)
• April 15 — Advance tax installment (if elected quarterly payment for new FY)
• April 30 — TDS return (Form 24Q/26Q/27Q) for Q4 of previous FY (January–March)
• April 30 — Professional Tax annual return (state-specific, varies by state)
• Begin preparation for statutory audit (appoint/reconfirm auditor if needed)

May

• May 15 — Issue Form 16 (TDS certificates) to employees for the previous FY
• May 30 — TCS return (Form 27EQ) for Q4 if applicable
• Close books of accounts for the previous financial year
• Begin transfer pricing documentation preparation

June

• June 15 — First installment of advance tax (15% of estimated tax) for current FY
• June 30 — Issue Form 16A (TDS certificates to non-salary deductees) for Q4
• Statutory audit fieldwork typically begins
• Review and update intercompany agreements for the new FY

July

• July 15 — FLA Return (Foreign Liabilities & Assets) to RBI — mandatory for all companies with FDI
• July 31 — Income Tax Return due date (for companies not requiring audit — rare for foreign subsidiaries)
• July 31 — TDS return for Q1 (April–June) of current FY
• Complete statutory audit and finalize financial statements

August

• Prepare board report and directors' report for the previous FY
• Prepare and circulate notice for Annual General Meeting (AGM)
• Finalize transfer pricing study and documentation

September

• September 15 — Second installment of advance tax (45% cumulative) for current FY
• September 30 — AGM must be held within 6 months of financial year end (by September 30 for March year-end companies)
• September 30 — DIR-3 KYC deadline for all directors (annual identity verification)
• Declare dividend at AGM (if applicable)

October

• October 15 — Form MGT-7/MGT-7A (Annual Return) to MCA — due within 60 days of AGM
• October 29 — Form AOC-4/AOC-4 CFS (Financial Statements) to MCA — due within 30 days of AGM
• October 31 — Income Tax Return for companies requiring audit (Form ITR-6)
• October 31 — Tax Audit Report (Form 3CB-3CD)
• October 31 — TDS return for Q2 (July–September)

November

• November 30 — Transfer Pricing Report (Form 3CEB) for companies with international transactions — due along with or before the tax return
• November 30 — Country-by-Country Report (if applicable, for groups with revenue above INR 5,500 crore)
• November 30 — Master File (if applicable, for groups with revenue above INR 500 crore)
• Begin advance tax planning for the current FY based on actual performance

December

• December 15 — Third installment of advance tax (75% cumulative) for current FY
• December 31 — GST Annual Return (GSTR-9) for previous FY
• December 31 — GST Reconciliation Statement (GSTR-9C, if turnover exceeds INR 5 crore) for previous FY
• December 31 — Half-yearly return for MSME outstanding payments (Form MSME-1, if applicable)
• Review compliance status and prepare for year-end

January

• January 15 — TDS return for Q3 (October–December)
• January 31 — Quarterly statement of TCS for Q3
• Begin tax planning for current FY year-end (investments, deductions)
• Review and plan for upcoming March 31 deadlines

February

• Union Budget typically presented on February 1 — review for changes affecting the subsidiary
• Collect investment proofs from employees for income tax computation
• Begin year-end closing procedures for March 31
• Review all intercompany transactions for transfer pricing alignment

March

• March 15 — Fourth installment of advance tax (100% cumulative) for current FY
• March 31 — End of financial year. Ensure all transactions are properly recorded.
• March 31 — Last date to make tax-saving investments (Section 80C etc.) for current FY
• March 31 — Updated return (ITR-U) deadline for FY two years prior (if applicable)
• Ensure all statutory registers are up to date
• Conduct board meeting to take note of year-end matters

Event-Based Compliance

In addition to the calendar-driven filings, certain events trigger immediate compliance requirements:

• New share allotment — FC-GPR to RBI within 30 days; PAS-3 to MCA within 15 days
• Director appointment/resignation — DIR-12 to MCA within 30 days
• Registered office change — INC-22 to MCA within 15/30 days depending on jurisdiction change
• Board meeting — minimum 4 per year, no gap exceeding 120 days between two meetings
• Significant Beneficial Ownership (SBO) — BEN-2 to MCA within 30 days of identifying SBO
• Change in authorized/paid-up capital — SH-7 to MCA within 30 days

Penalties for Late Filing

Penalties vary by authority but can be substantial. MCA filings attract additional fees of INR 100 per day of delay for most forms. Income tax late filing fees are INR 5,000 (or INR 1,000 for small companies). TDS late filing attracts INR 200 per day up to the TDS amount. EPFO delayed payment carries 5–25% per annum damages. More importantly, persistent non-compliance can lead to the company being flagged as "active non-compliant," directors being disqualified under Section 164(2) of the Companies Act, and the company being struck off the register under Section 248.