Investing globally is easier than ever — but it comes with a non-negotiable reporting obligation. Schedule FA (Foreign Assets) in your ITR requires every Resident and Ordinarily Resident (ROR) Indian to disclose foreign assets held during the calendar year. Failure to disclose a reportable foreign asset can attract a penalty of ₹10 lakh per assessment year under the Black Money (Undisclosed Foreign Income and Assets) Act, 2015, even where no additional tax is payable. Certain specified foreign assets (other than immovable property) are exempt from this penalty if their aggregate value does not exceed ₹20 lakh.
Who needs to file?
Schedule FA applies to Resident and Ordinarily Resident (ROR) taxpayers who hold foreign assets or earn income from sources outside India. NRIs and RNORs are generally exempt from Schedule FA reporting.
Most investors will file through ITR-2 (no business income); those with business or professional income use ITR-3. Since ITR-1 (Sahaj) does not contain Schedule FA, taxpayers required to disclose foreign assets cannot use ITR-1.
What must be reported?
Foreign assets held at any time during the relevant calendar year generally need to be disclosed, along with prescribed details such as acquisition, disposal, peak balance/value and closing balance where applicable:
Schedule FA applies even if the foreign asset generated no income during the year. A dormant foreign bank account, brokerage account, or foreign stock holding may still require disclosure despite producing no taxable income. Many investors incorrectly assume reporting is linked to income.
Foreign RSUs become a reportable foreign asset when they vest and shares are allotted to you. ROR taxpayers must disclose these holdings in Schedule FA — even if the shares are sold shortly after vesting, since the asset was held during the reporting period.
The penalty for non-disclosure
The ₹10 lakh penalty does not apply to certain foreign assets (other than immovable property) if their aggregate value does not exceed ₹20 lakh.
The penalty can apply even where no additional tax is payable — making accurate disclosure essential regardless of income. In cases of wilful concealment, the Act provides for imprisonment ranging from 6 months to 7 years, along with fines. Undisclosed foreign assets can also be taxed at 30% of asset value, with additional penalties significantly increasing total liability.
Investors should not assume foreign holdings are invisible. India receives foreign financial account information through the Common Reporting Standard (CRS) framework with participating jurisdictions. Information relating to US accounts may also be exchanged through FATCA-related arrangements between India and the United States.
Calendar Year vs Financial Year
Schedule FA runs on a different calendar than the rest of your ITR — a common source of confusion:
Calendar Year: Jan 1 – Dec 31
AY 2025–26 → report CY 2024
Financial Year: Apr 1 – Mar 31
AY 2025–26 → report FY 2024–25
If you bought a foreign asset in February 2024 and sold it in November 2024, it still must be disclosed for CY 2024 — even though you no longer hold it at year-end.
Currency conversion: SBI TTBR
Where foreign currency conversion is required for tax reporting purposes, the Income-tax Rules generally prescribe conversion using the SBI Telegraphic Transfer Buying Rate (TTBR) on the relevant date — not the interbank rate or your brokerage’s rate.
| Field | Date to use |
|---|---|
| Initial value / acquisition cost | Date of acquisition |
| Peak value | Date peak occurred |
| Closing value | December 31 |
| Income credited | Date income was credited |
Historical rates are available on the SBI forex rates page ↗. For older dates, request a certified rate certificate from an SBI branch.
The three values per asset
- Initial value — Jan 1 value if already held; acquisition cost if bought during the year.
- Peak value — Highest portfolio value at any point during Jan–Dec. Determine from available records; many taxpayers use brokerage statements and periodic valuation reports.
- Closing value — Value on Dec 31. Nil if sold earlier, but disposal details still required.
Tax on foreign income
Schedule FA discloses assets — it doesn’t compute tax. Income must be separately reported:
- Dividends — Taxed at slab rate as Other Income. Claim US withholding tax back as Foreign Tax Credit via Form 67 + Schedule FSI.
- Capital gains — Short-term (<24 months) at slab rate; long-term (24+ months) at 12.5% without indexation. The 12-month rule for Indian listed equities does not apply to foreign shares.
- RSUs — FMV at vesting is taxed as salary (reflected in Form 16); gains on subsequent sale are capital gains.
India has DTAAs with 90+ countries that can reduce withholding tax rates. See incometax.gov.in ↗ for treaty details. Also refer to the RBI LRS FAQ ↗ and OECD CRS overview ↗.
Filing checklist
Download Jan–Dec brokerage statements
From every foreign platform — trades, dividends, and corporate actions.
Identify peak value
Determine the highest value/balance during the year from available records. In practice, many taxpayers use brokerage statements and periodic valuation reports.
Source SBI TTBR for all relevant dates
Acquisition, peak, Dec 31, and any dividend credit dates.
File Form 67 if claiming FTC
Form 67 should be filed within the prescribed timeline to claim Foreign Tax Credit. Late filing can create complications and may jeopardise the claim.
Work with a CA to complete Schedule FA
Multi-currency, multi-asset reporting has many edge cases. Professional help is strongly recommended.
Frequently asked questions
I hold under ₹50,000 abroad. Do I still need to file?
Generally yes — there is no minimum threshold for disclosure. However, the ₹10 lakh penalty does not apply to certain non-immovable foreign assets whose aggregate value is below ₹20 lakh. The disclosure obligation itself still stands.
I sold all my US stocks before December 31. Still need to disclose?
Yes. Any asset held at any time during Jan–Dec must appear in Schedule FA. The closing value will be nil, but the disposal date and sale proceeds are still required.
My employer handles RSU tax via Form 16. Is that enough?
No. Your employer handles salary TDS, but Schedule FA is your personal obligation. You must file ITR-2 or ITR-3 and include Schedule FA yourself.
Can I file a revised ITR to add a missed Schedule FA?
Yes, before December 31 of the Assessment Year. After the revised return deadline expires, available remedies depend on the facts of the case and prevailing law. In some situations, an updated return (ITR-U) under Section 139(8A) may be available, though it carries additional tax and interest.
I’m RNOR — do I need Schedule FA?
Generally no — Schedule FA applies to ROR individuals. But RNOR status is transitional. Confirm with a CA each year rather than assuming it carries over.
I accidentally underreported the peak value. What now?
File a revised ITR promptly and document the reason. A proactive correction before any departmental notice is treated far more favourably than one made under scrutiny.