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ESOP & Employment

RSUs and ESPP from a foreign employer — when India taxes them

Your shares come from a US or other overseas employer, some vested while you were in India, and you can't tell which slice India taxes or how to avoid being taxed twice.

You work for — or used to work for — a foreign company such as Google, Microsoft or a US startup, and your pay includes RSUs or an ESPP. The shares are foreign, the broker is foreign (often Schwab, Fidelity or E*TRADE), and tax was usually withheld abroad. The question is what India does with all this once your residence shifts: which vests India can tax as salary, what happens when you sell, whether the tax already paid abroad can be set off, and what has to be disclosed on the Indian return. The answer turns almost entirely on where you were tax-resident on the day each tranche vested, and that is exactly the part most people get wrong.
Last reviewed: 10 June 202610 min readReviewed by Preetesh Maloo, CA

The short answer

For Indian tax, an RSU or ESPP is taxed at two moments. At vest (RSU) or purchase (ESPP) the discount or value received is salary — a perquisite under Section 17(2) — and India taxes it if you were a tax-resident of India when that tranche vested or was bought, even if the employer and shares are foreign. When you later sell the shares, the gain over that taxed value is capital gains, taxable in India only if you are resident in the year of sale (foreign shares are unlisted for India, so the holding-period and rate rules differ from listed Indian equity). Tax withheld abroad on the same income can usually be credited under the treaty by filing Form 67, and once you are a Resident and Ordinarily Resident the foreign shares and broker accounts must be reported in Schedule FA.

References on this page

  • Section 17(2) (perquisite — RSU vest / ESPP discount taxed as salary)
  • Section 5 / Section 6 (scope of income turns on residential status that year)
  • Section 90 + Form 67, Rule 128 (foreign tax credit under the treaty)
  • Schedule FA of the ITR (foreign assets — applies to Resident & Ordinarily Resident)

The two taxable moments: the vest and the sale

An RSU or ESPP is taxed twice over its life, and keeping the two events apart is what makes the whole thing tractable.

The first moment is the vest (for RSUs) or the purchase (for an ESPP). When RSUs vest, the market value of the shares you receive is treated as salary you've been paid in kind — a perquisite under Section 17(2). For an ESPP, the perquisite is the discount: the gap between what you paid and the market value on the purchase date. This is salary income, not capital gains, and your employer's payroll usually values it and reports it.

The second moment is the sale. Whatever the shares are worth above the value already taxed at vest is a capital gain when you sell. The cost for this gain is the value India (or the foreign country) already taxed as salary — you are not taxed twice on the same slice, because the salary-taxed amount becomes your cost base.

Which of these two India actually gets to tax depends on your residential status in the relevant year — and that is the next, and most important, distinction.

Why your residency on the vest date decides everything

India taxes a person on the basis of residential status for that specific year (Section 5, Section 6). For someone whose life straddles two countries, the same RSU grant can produce a vest that India taxes and a later sale that it doesn't — or the reverse.

When the event happensWhat India taxes
Vest while you are India-residentThe full vest value as salary, even though the shares are foreign
Vest while you are a non-residentOnly the part relating to days you worked in India during the grant-to-vest period
Sale while you are a non-residentGenerally nothing — a foreign-share gain to a non-resident is outside India's net
Sale while you are India-resident (ROR)The worldwide gain on the foreign shares

The trap is the returning NRI. You move back to India, your old foreign RSUs keep vesting on the original schedule, and those post-return vests are now Indian salary — often a surprise, because nothing on the foreign payslip flags it. The mirror trap is the leaver: you relocate abroad, sell shares while non-resident assuming India still taxes them, and over-report. The right treatment is decided tranche by tranche, against your status on each vest and each sale date.

Being taxed in two countries, and the credit that fixes it

Where a vest is taxed both abroad (withheld by the employer or broker) and in India (because you were resident when it vested), you are looking at the same income in two tax nets. The treaty between India and that country, read with the foreign tax credit rules, is what stops it being a genuine double hit.

The mechanism is a credit, not an exemption: India still computes its tax on the income, then allows you to set the foreign tax already paid against the Indian tax on that same income, up to the Indian rate. To claim it you file Form 67 before filing the return (Rule 128), supported by proof of the foreign tax — the foreign payslip, the broker's tax statement, or the foreign return.

The sale side needs care too. The US, for instance, may tax the capital gain on disposition; if you are also India-resident in the year of sale, India taxes the worldwide gain and a credit is again claimed through Form 67. Getting the cost base right on both sides — the vest value, the right exchange rate, the holding period — is what keeps the two computations consistent so the credit actually lands.

A worked example: Karthik moves back to Bengaluru

Karthik worked at a US tech firm in Seattle for four years and built up RSUs vesting quarterly. In mid-2024 he moved back to Bengaluru and stayed on remotely, then later joined an Indian employer. For the year he returns, he is India-resident.

Two tranches vested after his move, each worth about US$20,000. Because he was India-resident on those vest dates, both vests are Indian salary under Section 17(2) — roughly ₹33 lakh in total at the year's exchange rates — on top of whatever his Indian salary is. His US broker withheld US tax on the vests, so he files Form 67 and credits that US tax against the Indian tax on the same ₹33 lakh, paying the difference rather than the full amount twice.

When he sells a parcel a year later while still India-resident, the gain over the already-taxed vest value is a capital gain on foreign (unlisted-for-India) shares — taxed in India on the worldwide gain, with the vest value as the cost base and US tax on the sale, if any, credited again via Form 67. And because he is now a Resident and Ordinarily Resident, his US brokerage account and the unsold shares must be reported in Schedule FA of his return. The numbers are illustrative; the structure — vest as salary, sale as gains, credit for foreign tax, Schedule FA disclosure — is the part that holds.

Reporting the foreign shares: Schedule FA

Once you are a Resident and Ordinarily Resident for the year, India expects you to disclose foreign assets — including the foreign shares from your RSU/ESPP and the overseas brokerage account that holds them — in Schedule FA of the income tax return. This is a disclosure obligation that sits on top of the tax: even fully vested-and-taxed shares, and even shares sold during the year, generally have to be reported.

A non-resident, or a Resident-but-Not-Ordinarily-Resident (the typical status in your first year or two back), does not have a Schedule FA obligation for the same assets — another reason your status for the year drives the whole filing, not just the tax.

Schedule FA is detail-heavy: peak balance, closing value, dates and the right currency conversion for each holding and each account. It is also the part the department now cross-checks against information shared by foreign tax authorities, so under-reporting is increasingly visible. The companion tool below helps you assemble the figures before they go on the return.

What's involved

What the CA actually does

  1. 1

    We map every tranche to your residency on its date

    We take your grant and vesting schedule and your travel/residence history and work out, tranche by tranche, which vests India taxes as salary and which sales fall inside India's net — the step that decides everything else.

  2. 2

    We value the perquisite and reconcile it with foreign payroll

    For each India-taxable vest or ESPP purchase we compute the perquisite under Section 17(2) at the right exchange rate, and reconcile it against what your foreign employer and broker already reported, so the Indian and foreign figures line up.

  3. 3

    We claim your foreign tax credit through Form 67

    Where the same income was taxed abroad, we prepare and file Form 67 (Rule 128) with the supporting foreign-tax proof and claim the treaty credit (Section 90), so you pay the difference rather than tax twice over.

  4. 4

    We compute the gain on sale and set the cost base

    When you sell, we treat the gain above the already-taxed vest value as capital gains on foreign shares, fix the holding period and cost base correctly, and apply any further foreign-tax credit on the disposition.

  5. 5

    We prepare your Schedule FA disclosure

    Where you are Resident and Ordinarily Resident, we assemble the foreign shares and brokerage account details — peak balance, closing value, currency conversion — and file Schedule FA so the foreign assets are disclosed correctly alongside the tax.

What to have ready

Documents you'll typically need

  • Your RSU / ESPP grant letter and vesting schedule
  • Vest and purchase confirmations from the foreign broker (Schwab, Fidelity, E*TRADE, etc.)
  • Foreign payslips / W-2 or equivalent showing the income and tax withheld
  • Broker year-end tax statement (e.g. US 1099-B) and any sale confirmations
  • Your passport / travel record to establish residency on each vest and sale date
  • Foreign brokerage account statements (peak and closing balances) for Schedule FA
  • Your PAN and the foreign tax return, if one was filed

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 31 countries.

Frequently asked questions

Common questions

Foreign RSUs or ESPP and not sure what India taxes?

Send us your grant schedule and the years you moved. A practising CA will map each tranche, the foreign tax credit and your Schedule FA on a free call — no obligation.

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