The short answer
- Singapore runs off the company's financial year end. India runs off 31 March and fixed dates.
- A small Singapore subsidiary of a large Indian group usually needs an audit, because the whole group must pass the small company test.
- The Singapore numbers feed four Indian filings: consolidation, APR, FLA and transfer pricing. Late Singapore accounts make every one of them late.
Singapore side
| Filing | When | Notes |
|---|---|---|
| Estimated Chargeable Income | Within 3 months of year end | Waived if revenue is S$5m or less and ECI is nil |
| Annual general meeting | Within 6 months of year end | Private companies can dispense with it |
| Annual return | Within 7 months of year end | With financial statements, in XBRL where required |
| Corporate tax return | 30 November of the following year | Form C-S, C-S (Lite) or Form C |
| GST return | One month after each quarter | If GST-registered |
| Employee income (IR8A) | 1 March | For every employee |
| Transfer pricing documentation | By the tax return due date | When thresholds are crossed |
| Certificate of residence | Each year a treaty claim is made | Via myTax Portal |
India side (your Indian chartered accountant)
| Filing | When | Notes |
|---|---|---|
| Form ODI | Before each investment | Through the bank |
| FLA return to the RBI | 15 July | Foreign assets as at 31 March |
| Transfer pricing accountant's report | With the return, for most groups 31 October | Transactions with the Singapore company |
| Master file (Form 56) | With the income tax return | Part A for every constituent entity; Part B above thresholds |
| Annual Performance Report | 31 December | Built on the Singapore accounts |
| Country-by-country report (Form 59) | 12 months after year end | Groups above INR 6,400 crore |
| Consolidated financial statements | With the parent's annual accounts | Singapore numbers inside the group accounts |
The audit rule. A Singapore company is exempt from audit only if it is a small company and, if it belongs to a group, the whole group (foreign parent included) also passes the small company test on consolidated numbers. ACRA is reviewing the thresholds; see does my company need an audit.
Make the two calendars one
- Pick a 31 March year end for the Singapore company, so its numbers line up with the parent
- Close the Singapore books within 30 days of year end, so the Indian consolidation is not waiting
- Keep one shared calendar between the Singapore team and the Indian CA
- Review the intercompany balances quarterly, not at year end
A worked year: 31 March year end
Here is how the dates fall for a Singapore subsidiary of an Indian parent with a year ending 31 March 2026. Dates move with your own year end, but the order does not.
| Date | Filing | Country |
|---|---|---|
| April to May 2026 | Close the books, agree intercompany balances, draft accounts for the parent's consolidation | Both |
| 30 June 2026 | ECI for the year to 31 March 2026, unless waived | Singapore |
| 15 July 2026 | FLA return, foreign assets as at 31 March 2026 | India |
| 30 September 2026 | AGM, or accounts sent to members if the AGM is dispensed with | Singapore |
| 31 October 2026 | Annual return with financial statements | Singapore |
| 31 October 2026 (typical) | Indian tax return and transfer pricing report of the parent | India |
| 31 December 2026 | Annual Performance Report, built on the Singapore accounts | India |
| 1 March 2027 | Employee income for calendar year 2026 | Singapore |
| 30 November 2027 | Corporate tax return for YA2027, covering the year to 31 March 2026 | Singapore |
Notice the last row. Singapore's tax return for a March year end is filed a long time after the year closes. That is helpful for cash, but it means the tax computation is often prepared by people who did not close the books. Prepare it while the year is fresh, at the ECI stage.
What a missed date costs
- ACRA: a late annual return attracts a late lodgement penalty, currently S$300 if filed within three months of the due date and S$600 after that, and repeated defaults can lead to prosecution of directors.
- IRAS: a late tax return can bring an estimated assessment, a composition fine and, if ignored, summons. Late GST returns attract S$200 for each month late.
- India: late APR or FLA filings need a late submission fee, and block further ODI through the bank until cleared.
None of these is large on its own. The real cost is management time and the record they leave, which banks and investors see.
Questions people ask
What are the main Singapore deadlines after year end?
ECI within 3 months (unless waived), AGM within 6 months, annual return within 7 months, and the corporate tax return by 30 November of the following year.
Which Indian filings depend on the Singapore accounts?
Consolidation, the Annual Performance Report (31 December), the FLA return (15 July) and the transfer pricing report. Late Singapore accounts make all of them late.
Talk it through with an adviser
Tell us your structure and deadlines. We reply with what applies to you and a fixed-fee proposal.
Sources
- ACRA: Audit exemptions and the small company concept
- IRAS: Estimated Chargeable Income filing
- IRAS: Transfer pricing
- RBI: Master Direction, Overseas Investment (updated 1 April 2026)
- Treelife: Master file and CbCR in India, old and new forms (secondary source)
General information only, last reviewed 11 November 2026. It is not advice for your situation. Laws and practice change, and the official sources linked above prevail. Speak to a qualified adviser before you act. Northwise does not file with Indian authorities; India-side work is done by independent licensed firms.
