A foreign-owned Indian subsidiary answers to five regulators at once – MCA, the tax department, GST, RBI and the labour authorities – each with its own calendar. Miss one filing and the fines run ₹100 per day uncapped (ROC), deactivate your directors’ DINs, or park your export remittances. This is the master calendar for a private-limited subsidiary, organised the way a controller actually works: monthly rhythm, quarterly beats, and the annual season.
The monthly rhythm
| Date | Obligation |
|---|---|
| 7th | Deposit TDS deducted last month (March TDS: by 30 April) |
| 11th | GSTR-1 (outward supplies) |
| 15th | PF (20+ employees) and ESI (10+ employees, wages ≤ ₹21,000) payments + returns |
| 20th | GSTR-3B – note: liability now hard-locked from auto-populated GSTR-1/1A, so fix errors in GSTR-1A before the 20th |
| State-wise | Professional tax (e.g. Karnataka 20th) |
| Within 30 days of invoice / month-end | SoftEx for software exporters (monthly EDF from October 2026) |
| Event-based | FC-GPR 30 days from any allotment; ECB-2 within 7 days of a drawdown/servicing month-end |
The quarterly beats
| Due | Obligation |
|---|---|
| 15 Jun / 15 Sep / 15 Dec / 15 Mar | Advance tax – 15% / 45% / 75% / 100% cumulative |
| 31 Jul / 31 Oct / 31 Jan / 31 May | TDS quarterly statements (24Q/26Q/27Q) |
| Quarterly | Board meetings – minimum 4 a year, gap ≤ 120 days; keep the resident-director (182 days) test alive |
The annual season (for a 31 March year-end)
| Due | Obligation |
|---|---|
| 30 Apr | MSME Form 1 (Oct–Mar half; only if micro/small supplier dues ran past 45 days) |
| 31 May | SFT (Form 61A) where applicable; Q4 TDS statements |
| 30 Jun | DPT-3 – parent loans and ECBs are “exempt deposits” but must be reported |
| 15 Jul | FLA return on FLAIR – every entity with outstanding FDI (audited revision by 30 Sep) |
| 30 Sep | AGM (6 months from year-end; first AGM 9 months) · DIR-3 KYC for every DIN holder including foreign directors (miss it: DIN deactivated + ₹5,000) · tax audit for non-TP companies |
| 14/15 Oct | ADT-1 (auditor) within 15 days of AGM |
| 29/30 Oct | AOC-4 (financials) within 30 days of AGM · MSME Form 1 (Apr–Sep half) |
| 31 Oct | Form 3CEB (transfer pricing report – every AE transaction) + tax audit for TP companies · ITR for non-TP companies |
| 29 Nov | MGT-7 (annual return) within 60 days of AGM – a foreign subsidiary never qualifies as a “small company”, so no MGT-7A shortcut |
| 30 Nov | ITR for TP companies · Master File (3CEAA) where thresholds hit |
| 31 Dec | GSTR-9 annual return (+ 9C reconciliation above ₹5 crore) |
| 31 Mar | LUT renewal (RFD-11) for the next year’s zero-rated exports – before 1 April, every year |
Threshold checks – what switches on as you grow
| Requirement | Trigger |
|---|---|
| CSR (2% of profits) | Net worth ₹500cr / turnover ₹1,000cr / net profit ₹5cr – the profit test catches successful cost-plus captives surprisingly early |
| Internal auditor | Turnover ₹200cr or borrowings ₹100cr (private company) |
| Ind AS | Net worth ₹250cr (unlisted); parent’s IFRS status does not force it – voluntary adoption (irrevocable) is common for group alignment |
| CARO reporting | Most funded subsidiaries are covered (the small-company escape needs paid-up + reserves ≤ ₹1cr, borrowings ≤ ₹1cr, revenue ≤ ₹10cr) |
| Audit trail software | All companies – the ERP (SAP/NetSuite) needs India audit-trail configuration; auditors report on it |
| POSH committee | 10+ employees – ICC + annual report to the District Officer |
| Secretarial audit | Private companies exempt (unless subsidiary of a qualifying public company) |
Want the calendar run for you?
We operate the full compliance cycle for foreign subsidiaries – MCA, tax, GST, FEMA and payroll – with a monthly closing discipline your parent’s controller will recognise.
Talk to My Cloud AccountantFrequently asked questions
What are the key annual filings for a foreign subsidiary in India?
AGM by 30 September, AOC-4 and MGT-7 after it, DPT-3 by 30 June, FLA by 15 July, DIR-3 KYC by 30 September, tax audit and Form 3CEB by 31 October, ITR by 30 November (TP companies), GSTR-9 by 31 December, and the LUT renewal by 31 March.
Do foreign directors need DIR-3 KYC?
Yes – every DIN holder files by 30 September regardless of residence. Missing it deactivates the DIN (blocking all their filings) and costs ₹5,000 to reactivate.
Is Form 3CEB required even for small intercompany transactions?
Yes – 3CEB covers every international transaction with an associated enterprise regardless of value, due 31 October. Full documentation under Rule 10D kicks in above ₹1 crore of transactions.
What is the penalty for late AOC-4 or MGT-7?
₹100 per day per form, uncapped – a year’s delay on both forms costs about ₹73,000 before anything else. Officer penalties can add to it.
Due dates per the Companies Act 2013, Income-tax Act (FY 2026-27 calendar), GST law as amended July 2025 and FEMA reporting rules. Dates assume a 31 March year-end; extensions are notified year to year. Last reviewed: July 2026.