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Certificates, Foreign Tax/Legal

The Indian-asset data pack behind your foreign tax disclosure

Your foreign return asks for figures on your Indian accounts and assets, and pulling the right numbers out of Indian statements is its own headache.

Your tax return abroad requires you to disclose your Indian financial accounts and assets, and the figures it wants are not the ones an Indian statement shows on its face. A US FBAR wants the highest balance each account touched during the year; Form 8938 wants asset values and the income each one produced; Canada's T1135 wants the cost amount of each foreign property; a UK return wants your Indian income on its foreign pages. Getting these wrong, or guessing, creates real exposure abroad. A practising chartered accountant assembles the Indian-side data. The maximum balances, cost amounts, income and India tax paid, in a clean pack your foreign preparer can drop into the return.
Last reviewed: 10 June 20269 min readReviewed by Preetesh Maloo, CA

The short answer

A chartered accountant assembles the Indian-side data your foreign tax filing needs: the maximum balance each Indian account reached during the year (FBAR, FinCEN Form 114), asset values and income each asset produced (Form 8938/FATCA), cost amount and income per Indian property (Canada's Form T1135), Indian income for UK Self Assessment foreign pages, and a certificate of taxes paid in India to support a Foreign Tax Credit. The pack is built on your filed Indian return and statements, with a UDIN where a certificate is issued. The CA prepares the Indian-side data; the foreign return is filed by you or your foreign preparer.

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Where the foreign return and the Indian record diverge

The figure each foreign form wants is rarely what an Indian statement prints. A bank statement shows a closing balance; an FBAR wants the single highest balance the account reached at any point in the year. A demat statement shows holdings; Form 8938 and T1135 want a value and the income produced, T1135 also wants the cost amount (what you paid, not today's market price).

The CA fills the Indian-side gap: reading the rupee statements, finding the right data point for each form, and handing your preparer figures they can rely on. The CA prepares and, where appropriate, certifies the Indian-asset data; you or your overseas preparer complete and file the foreign return under that country's rules.

What each filing needs from the Indian side

Each disclosure asks for a different cut of the same underlying assets.

Foreign filingIndian data the CA assembles
FBAR (FinCEN Form 114)Max balance per Indian account during the year
Form 8938 (FATCA)Asset values + income each asset produced
Form T1135 (Canada)Cost amount + income per Indian asset
UK foreign pagesIndian income, gross and tax deducted

For an FBAR, the pack lists each reportable Indian account and its maximum balance during the year. FBAR generally applies once the aggregate of foreign accounts crosses a threshold. The commonly cited figure is USD 10,000 in aggregate; your US preparer applies the current rule. For Form 8938, the pack pairs each Indian asset with its value and the interest, dividends, gains or rent it produced. For T1135, it gives the cost amount of each Indian property along with its income and any gain on disposal. For a UK return, Indian income is set out gross, with the Indian tax deducted shown separately to feed a credit claim.

The certificate of taxes paid in India, for a Foreign Tax Credit

When the same income is taxed in both India and your country of residence, the foreign country usually lets you claim a Foreign Tax Credit for the Indian tax. Claiming it requires evidenced proof of how much Indian tax was actually paid.

A chartered accountant issues a certificate of taxes paid in India: the income, the Indian tax deducted or paid, tied to your Form 26AS / AIS and filed return, on letterhead with a UDIN. The credit mechanics, limits, timing, forms, are governed by the other country's rules and applied by your preparer. The CA certifies what was paid in India; the credit claim is the foreign filing's job.

A worked example: a US NRI's FBAR and 8938 season

Sneha, an NRI in California, has an NRO savings account, two fixed deposits and a mutual fund portfolio in India. Her US preparer needs figures for her FBAR and Form 8938, and proof of the Indian tax on her FD interest for a Foreign Tax Credit.

A chartered accountant builds one data pack: each account's highest balance for the FBAR; each account and the mutual fund with year-end value and income for Form 8938; and a UDIN-backed certificate of taxes paid in India on her FD interest, tied to Form 26AS and her filed return.

Sneha's US preparer applies the US thresholds, files the FBAR and the 8938, and claims the Foreign Tax Credit. The CA's role ends at accurate, verifiable Indian data; the US filing decisions stay with the preparer.

If you file in the UK: the India-side pack for your SA106 foreign pages

A UK resident reports overseas income on Self Assessment foreign pages (SA106). Each line asks for income received and foreign tax paid on it, for a Foreign Tax Credit Relief claim. Indian property gains go on the capital gains pages (SA108), not the SA106, so the pack labels the gain separately.

SA106 / SA108 lineIndia-side figure we hand over
Foreign savings (interest)NRO interest, gross, with TDS shown
Foreign savings (dividends)Indian dividends, gross, with TDS shown
Foreign propertyIndian rent, gross, less Indian expenses
Capital gains (SA108)Gain on Indian property or shares, with India tax paid

Two India-side points. First, NRE and FCNR interest is exempt in India, no TDS to credit, but is usually taxable in the UK, so we list it with a zero-India-tax note. Second, we present tax per income type, because Foreign Tax Credit Relief is capped at the UK tax on that same income. We prepare the rupee figures and India-tax evidence; your UK accountant applies the exchange basis and completes the SA106 and SA108.

If you file in Australia: the India-side evidence for your Foreign Income Tax Offset

An Australian resident who paid tax in India on the same income can claim a Foreign Income Tax Offset (FITO) on the Australian return. The ATO wants two things: the foreign income included in the return, and written evidence the foreign tax was actually paid. The India-side pack we build.

For each Indian income stream, NRO interest, dividends, rent, a capital gain. We set out the income and the Indian tax borne on it, tied to your Form 26AS / AIS and filed return. Where it helps, we issue this as a certificate of taxes paid in India on letterhead with a UDIN.

Two India-side points: the pack distinguishes tax already deducted or paid from any still outstanding (the FITO only covers tax actually paid); and NRE/FCNR interest is exempt in India, so there is no Indian tax to offset on it. The FITO calculation and limit are applied on the Australian return by your preparer.

If you file in Spain: the India-side asset inventory for Modelo 720

Spain's Modelo 720 is an informational declaration, not a tax return, listing assets held outside Spain, generally filed by 31 March for the prior year. The EUR 50,000 reporting threshold applies per category, not across your total assets.

Modelo 720 categoryIndia-side detail we list
AccountsNRO / NRE / FCNR balances, year-end and last-quarter average
SecuritiesShares, mutual funds, bonds, year-end value
Real estateIndian property, purchase value and date

For accounts we give the closing balance and the last-quarter average; for securities the year-end value; for property the acquisition value and date. NRE/FCNR accounts appear on the inventory even though their interest is exempt in India, Modelo 720 is about the asset, not the tax. After a first filing, a fresh declaration is generally needed only where a category rises by more than EUR 20,000 or an item is disposed of. We prepare the rupee values; the thresholds, valuation rules and euro conversion are for you or your Spanish adviser.

If you file in Germany: the India-side figures for your Anlage AUS

A German resident reports foreign income and the tax paid on it on the Anlage AUS ("Ausländische Einkünfte"). Germany relieves double taxation either by crediting the foreign tax (Anrechnung) or, where a treaty exempts the income, by counting it only to set the rate on German income. Either way the German side needs the same two India figures per income type: gross income and Indian tax paid.

The pack sets out each Indian source's income and Indian tax deducted or paid, tied to Form 26AS / AIS and your filed return, with income types separated, interest, dividends, rent, capital gains, since the credit is worked out per category. Where Germany credits Indian tax, we supply a UDIN-backed certificate of taxes paid in India as the evidence behind the Anlage AUS entry.

The NRE/FCNR point applies here too: that interest is exempt in India, so we list it with the India-tax field at nil rather than omit it, keeping the German return complete. The credit limit, treaty treatment and euro conversion are applied by you or your German preparer.

What's involved

What the CA actually does

  1. 1

    We map your Indian assets to what each form needs

    We identify which Indian data point each foreign filing requires, FBAR, Form 8938, T1135, UK foreign pages, so nothing is missed and nothing irrelevant clutters the pack.

  2. 2

    We pull the right figure from each Indian statement

    We read your rupee statements to extract the specific data each form wants, maximum balance for an FBAR, value and income for Form 8938, cost amount for T1135, rather than the closing balance the statement shows on its face.

  3. 3

    We assemble the income and India-tax data

    For each Indian asset we set out the income it produced and the Indian tax deducted or paid on it, tied to your Form 26AS / AIS and filed return, so it feeds both the foreign disclosure and any Foreign Tax Credit claim.

  4. 4

    We issue a certificate of taxes paid in India

    Where your foreign return claims credit for Indian tax, we certify the Indian tax paid on the relevant income on letterhead with a UDIN, tied to Form 26AS and your return, so your preparer has verifiable evidence for the credit.

  5. 5

    We hand off cleanly to your foreign preparer

    We deliver the Indian-side data in a clear pack and stop there. The foreign return. The thresholds, the form choices, the credit mechanics, is filed by you or your overseas preparer under that country's rules, with our data behind it.

What to have ready

Documents you'll typically need

  • List of the foreign filings you need data for (FBAR, 8938, T1135, UK pages)
  • Indian bank, NRO / NRE and FD statements for the full year
  • Demat and mutual fund statements with year-end values
  • Property papers showing the cost / purchase price, for T1135 cost amount
  • Your filed Indian income tax return (ITR-V / acknowledgement)
  • Form 26AS / AIS showing income and Indian tax deducted
  • PAN and a photo ID of the person the data pack is for

Your destination country can change the details

Requirements differ from one consulate, university and visa route to the next, how recent the figures must be, how long funds must have been held, and which certificates are mandatory. We assemble the documents around the exact checklist you're applying under. To see how India's tax treaty with your country of residence affects related filings, set your country below or compare all 46 countries.

References on this page

  • FinCEN Form 114 (FBAR), US Report of Foreign Bank and Financial Accounts
  • Form 8938, US Statement of Specified Foreign Financial Assets (FATCA)
  • Form T1135, Canada Foreign Income Verification Statement
  • ICAI UDIN mandate, Unique Document Identification Number on certificates
  • Form 26AS / Annual Information Statement. India income and tax paid

Frequently asked questions

Common questions

No. We prepare the Indian-side data, maximum balances, asset values, cost amounts, income and India tax paid, and where appropriate certify it. Your foreign return, including FBAR, Form 8938, T1135 or UK foreign pages, is filed by you or your overseas tax preparer under that country's rules, using our data.

An FBAR (FinCEN Form 114) asks for the highest balance each account reached during the year, not the closing balance your statement prints. We read the year's statements to identify that maximum for each reportable account, which is the figure your US preparer needs.

An FBAR generally applies once the aggregate of your foreign financial accounts crosses a threshold at some point during the year. The commonly cited figure is USD 10,000 in aggregate. The current rule and how it is tested are applied by your US preparer; our role is to supply the accurate maximum-balance data so they can decide and file.

Form 8938 (FATCA) generally looks at the value of the asset and the income it produced. Canada's T1135 asks for the cost amount, broadly what you paid for the asset, along with its income and any gain on disposal. We pull the right figure for each, because they are not the same number.

Where the same income is taxed in both India and your country of residence, the foreign country usually allows a Foreign Tax Credit for the Indian tax. The certificate sets out the Indian tax actually paid on that income, tied to your Form 26AS and filed return and issued with a UDIN, so your foreign preparer has verifiable evidence to support the credit they claim.

The underlying Indian figures are in rupees, and we present them clearly with the rupee amounts. Foreign forms generally require conversion to the foreign currency on a basis that country specifies; that conversion is applied on the foreign return by your preparer, so the credited and reported amounts follow the foreign rules.

We give your accountant the Indian income for the year, gross, with Indian tax deducted set out separately to support a Foreign Tax Credit Relief claim, plus the account and asset details. All in rupees. Your accountant applies the exchange basis and completes the SA106 and SA108 under UK rules.

We assemble your Indian income for the year and the Indian tax actually paid on it, tied to Form 26AS / AIS and your filed return. The India-side support a FITO claim rests on. Where helpful we issue this as a UDIN-backed certificate of taxes paid in India. The FITO calculation and cap are governed by Australian rules and applied by your preparer.

Yes. We pull year-end balances and valuations of your Indian accounts and assets for Spain's Modelo 720 and the Netherlands Box 3 wealth basis, and your Indian income for Germany's Anlage AUS. We present the rupee amounts with their source; the thresholds, valuation dates and conversion are applied on the foreign filing by you or your preparer.

Yes. Some countries tax the interest that builds up annually inside Indian retirement balances, not just on withdrawal. We prepare an accrual statement showing the interest credited to your EPF and PPF for the year and the closing balances, drawn from your statements and passbook entries. Whether and how the accrual is taxed is decided on the foreign return under that country's rules.

We can prepare the Indian facts your bank's CRS / FATCA self-certification form asks for. Your Indian tax identification number (your PAN), your Indian address, and the residency and status details the form requires, so you can complete it accurately. The self-certification itself is a declaration you sign and give to your foreign bank; we assemble and confirm the Indian-side information that goes into it rather than submitting it for you.

Yes. We prepare a CA-certified summary that restates your Indian income and the TDS shown on your Form 16 and Form 26AS / AIS in clear terms, tied to your filed return, on letterhead with a UDIN. Your accountant and any reviewer can confirm it on ICAI's portal and use it as Indian-side evidence for a foreign filing or Foreign Tax Credit claim.

The exceptions that change the answer

Where the general rule stops applying to you

Every rule below has a carve-out, a cut-off date or a condition that flips the answer. These are the ones that decide real cases.

FCNR(B) deposit tenure

Right now: 1 to 5 years; term deposits only, no savings variant

Where it works differently

The holder returns to India permanently
The deposit may run to maturity, then converts to RFC. Interest stays exempt while the holder is RNOR.
Master Direction on Deposits and Accounts.
Premature withdrawal before 12 months
No interest is payable.
Standard RBI condition on FCNR(B).

Commonly got wrong

  • FCNR accounts work like a savings account. FCNR(B) is a term deposit only, 1 to 5 years.FCNR(B) is a fixed deposit in foreign currency, one to five years. There is no FCNR savings account.

FBAR filing threshold

Right now: USD 10,000 aggregate at any point in the calendar year

Where it works differently

The threshold is tested
It is AGGREGATE across all foreign accounts, and momentary. A single day above the line triggers the year.
31 CFR 1010.350.
Form 8938 is also considered
Different thresholds, different asset definitions. Both usually apply, not one or the other.
Separate regimes.

Commonly got wrong

  • FBAR is needed only if the balance is over USD 10,000 at year end. Any point in the year counts.At any time during the year.

Canadian T1135 threshold

Right now: CAD 100,000 total COST of specified foreign property

Where it works differently

The Indian property is personal-use
Excluded from specified foreign property. A rented-out flat is NOT excluded.
Definition in s.233.3.
The test is applied
It is COST, not market value.
Statutory wording.

Commonly got wrong

  • T1135 uses market value. It uses cost.T1135 is triggered by the COST of specified foreign property exceeding CAD 100,000, not by its market value.

India's automatic exchange of financial account information

Right now: FATCA in force: Indian banks and funds report US persons' accounts to the IRS via India's Form 61B channel

Where it works differently

A US-citizen or green-card-holder NRI holds an Indian bank or mutual-fund account
The account is reported to the IRS under FATCA even though the person files Indian returns as an NRI. It is dual reporting, not either/or.
FATCA reporting turns on US-person status, independent of Indian residential status.

Commonly got wrong

  • CRS covers the US too, so a US-based NRI is exchanged under CRS. The US is not a CRS participant. US persons are caught only under FATCA.A UK, UAE or Canada NRI is reported under CRS; a US-person NRI is reported under FATCA.

Need the Indian-asset data behind your FBAR, 8938 or T1135?

Tell us which foreign filings are in play and send your Indian statements. A practising CA will scope the data pack your preparer needs on a free call, no obligation.

No card, no obligation. All certification and filing work is handled by ICAI-registered practising Chartered Accountants.