Summary: Indian taxpayers owning companies in the UAE may have extensive income-tax reporting obligations in India that are separate from compliance under the RBI overseas-investment framework. The principal requirement depends on the taxpayer’s residential status, with Schedule FA generally relevant to resident and ordinarily resident taxpayers holding foreign assets, financial interests, foreign accounts or signing authority. UAE company shares may require disclosure as foreign equity interests, while broader ownership or beneficial interests may also require financial-interest reporting. Personal UAE bank accounts and signing authority over corporate bank accounts must be separately examined. The taxpayer may additionally need to consider directorship and unlisted-share disclosures in the applicable ITR. Foreign salary, directors’ fees, dividends, interest and capital gains must be reported under the appropriate income heads and may also require Schedule FSI, Schedule TR and Form 67 where foreign tax credit is claimed. Schedule FA generally follows the specified calendar-year reporting period, which differs from the Indian financial year used for income computation. Dormant companies, nil-balance accounts and investments producing no income can still trigger disclosure requirements. UAE company owners should also examine POEM, beneficial ownership, foreign-tax-credit rules, Black Money Act exposure and correction options for earlier omissions. Maintaining a comprehensive annual reconciliation between UAE corporate records, bank accounts, RBI filings and the Indian income-tax return is therefore essential.
- Foreign Asset Reporting for Indians Owning UAE Companies
- Residential Status Determines the Reporting Obligation
- What Schedule FA Covers
- Which ITR Form Should Be Used?
- Reporting the UAE Shareholding
- Initial, Peak and Closing Value
- Financial Interest in the UAE Company
- Reporting the UAE Company’s Bank Account
- A Personal UAE Bank Account Requires Separate Reporting
- Directorship and Unlisted-Share Disclosures
- Reporting Period: Calendar Year Versus Financial Year
- Does a Dormant UAE Company Need to Be Reported?
- Is the UAE Company’s Profit Taxable Directly to the Shareholder?
- Place of Effective Management
- Salary and Directors’ Fees
- Dividends From a UAE Company
- Capital Gains on Sale of UAE Company Shares
- Schedule FSI
- Schedule TR and Foreign Tax Credit
- Form 67
- Information Exchange Makes Reconciliation Important
- Consequences of Non-Disclosure
- Correcting an Earlier Omission
- Practical Example
- Documents UAE Company Owners Should Maintain
- Common Reporting Mistakes
- Annual Compliance Checklist
- Conclusion
- Disclaimer
- References
Foreign Asset Reporting for Indians Owning UAE Companies
Owning a company in Dubai or another part of the United Arab Emirates has become increasingly common among Indian entrepreneurs. A person may establish a UAE free-zone company, acquire shares in a mainland limited liability company, become a director or operate the company’s UAE bank account.
The company may be entirely legitimate and properly reported under the Reserve Bank of India’s overseas-investment framework. That does not, however, complete the owner’s Indian income-tax obligations.
An Indian taxpayer may separately be required to disclose the UAE shareholding, financial interest, bank-account authority and income in the Indian income-tax return. These disclosures can apply even where:
- The UAE company earned no profit;
- No dividend was distributed;
- The company remained dormant;
- The shares were acquired at nominal value;
- The bank account had a low or nil closing balance;
- The investment was already reported to the RBI;
- The person did not transfer money back to India; or
- The company’s income was taxed in the UAE.
Foreign-asset reporting is driven primarily by the taxpayer’s Indian residential status and the nature of the foreign interest. It is not determined merely by whether the asset produced taxable income.
Residential Status Determines the Reporting Obligation
The first step is to determine the individual’s residential status under Indian income-tax law for the relevant year.
An individual may be classified as:
- Resident and ordinarily resident;
- Resident but not ordinarily resident; or
- Non-resident.
Schedule FA is generally applicable to a resident and ordinarily resident taxpayer holding foreign assets or specified foreign interests. The Income Tax Department’s guidance states that Schedule FA need not ordinarily be completed by a person who is non-resident or resident but not ordinarily resident.
This distinction is important for entrepreneurs who move between India and the UAE.
A UAE residence visa, Emirates ID or Dubai company ownership does not automatically make a person non-resident in India. Indian tax residence is determined under Indian law by applying the relevant physical-presence and additional residence conditions.
Similarly, FEMA residence and income-tax residence serve different purposes. A person may have correctly made an overseas investment under FEMA but still qualify as resident and ordinarily resident for Indian income-tax purposes.
Residential status should therefore be determined separately for every relevant year.
What Schedule FA Covers
Schedule FA forms part of the Indian income-tax return and captures details of foreign assets and income from sources outside India.
The disclosure is not restricted to assets registered directly in the taxpayer’s name. It can cover an asset or account in which the taxpayer is:
- The legal owner;
- A beneficial owner;
- A beneficiary;
- A person holding a financial interest; or
- A person having signing authority.
The official guidance describes a beneficial owner as an individual who directly or indirectly provided the consideration for an asset held for the immediate or future benefit of that individual or another person.
A beneficiary is generally an individual who receives an immediate or future benefit from an asset where the consideration was provided by someone else.
These definitions matter where:
- A spouse or relative is named as the UAE shareholder;
- Shares are held through a nominee;
- One family member provided the investment money;
- A UAE holding company owns the operating company;
- The individual is a beneficiary of a foreign trust; or
- The legal documentation does not reflect the person exercising economic ownership.
The reporting analysis should follow the legal and beneficial ownership of the arrangement, not merely the name appearing on the trade license.
Which ITR Form Should Be Used?
ITR-1 and ITR-4 do not contain Schedule FA. The Income Tax Department advises taxpayers with reportable foreign assets or foreign income not to use these simplified forms.
Depending on the taxpayer’s income and circumstances, the appropriate return may commonly be:
- ITR-2, where the individual does not have income from business or profession; or
- ITR-3, where the individual has income from business or profession.
For example, an Indian resident who owns shares in a Dubai company and receives only salary, dividends and capital gains may ordinarily examine ITR-2. An individual carrying on a separate business or profession may need to use ITR-3.
The correct form depends on the complete income profile. The mere fact that a person owns shares in a UAE company does not, by itself, mean that the company’s business income becomes the shareholder’s personal business income.
Reporting the UAE Shareholding
Shares or ownership interests in a UAE company may need to be reported under the section dealing with foreign equity and debt interests.
For Assessment Year 2026–27, the notified Schedule FA requires details of foreign equity and debt interests held at any time during the calendar year ending 31 December 2025. The requested information includes the entity’s identity, acquisition date, initial value, peak value, closing value, gross amounts credited and sale or redemption proceeds.
For a UAE company, the taxpayer should ordinarily assemble:
- Legal name of the company;
- Registered address;
- Country and jurisdiction;
- Postal or ZIP code;
- Nature of the entity;
- Date on which the ownership interest was acquired;
- Original subscription or acquisition amount;
- Percentage of ownership;
- Additional capital contributed;
- Peak value during the reporting period;
- Closing value;
- Dividends or other amounts received; and
- Sale or redemption proceeds, where applicable.
An ownership interest in a free-zone establishment or mainland limited liability company should not be ignored simply because the interest is not described as a conventional share certificate. The company’s memorandum, share register, incorporation certificate and ownership documents should be examined to identify the foreign equity interest.
Initial, Peak and Closing Value
Schedule FA may require more than the original investment amount.
Depending on the relevant table, the taxpayer may need to report:
- Initial value of the investment;
- Peak value during the calendar year;
- Closing value at the end of the relevant calendar year;
- Gross income paid or credited; and
- Gross sale or redemption proceeds.
The closing value should not automatically be assumed to be the original share capital. Changes may arise through:
- Additional capital contributions;
- Rights issues;
- Bonus shares;
- Shareholder restructuring;
- Partial sale;
- Share redemption;
- Capital reduction;
- Merger or reorganization; or
- Changes in the value used under the applicable reporting instructions.
The prescribed return instructions and currency-conversion rules should be followed for the relevant assessment year.
The taxpayer should preserve the exchange-rate calculation used to convert UAE dirhams into Indian rupees. Applying one convenient year-end rate to every amount may be incorrect where different values must be converted with reference to different dates.
Financial Interest in the UAE Company
Schedule FA also contains a separate table for a financial interest in an entity outside India.
A financial interest can extend beyond shares held directly in the taxpayer’s name. It may include an interest where:
- The resident taxpayer is the legal owner of a financial account;
- An agent or nominee holds an interest on the taxpayer’s behalf;
- The taxpayer directly or indirectly owns shares or voting power in a foreign company;
- The taxpayer has an interest in a foreign partnership;
- The taxpayer has an ownership or beneficial interest in a foreign trust; or
- The taxpayer has voting rights, equity, assets or an interest in profits of another foreign entity.
The table may require:
- Name and address of the entity;
- Nature of the entity;
- Nature of the taxpayer’s interest;
- Date from which the interest was held;
- Total investment at cost;
- Income accrued from the interest;
- Nature of that income; and
- The ITR schedule in which taxable income has been offered.
A UAE company owner may therefore need to examine both the foreign equity table and the financial-interest table. The return should be completed according to the applicable form instructions, avoiding accidental omission or inconsistent duplication.
Reporting the UAE Company’s Bank Account
A UAE company’s bank account belongs to the company, not automatically to its shareholder or director.
However, Schedule FA contains a separate reporting requirement for foreign accounts over which the taxpayer has signing authority, where the account has not already been reported in the other applicable tables.
This can affect an Indian-resident director, manager or owner who is authorized to operate the Dubai company’s bank account.
The required information may include:
- Name and address of the bank;
- Country and country code;
- Name of the account holder;
- Account number;
- Peak balance or investment during the period;
- Whether income accrued is taxable in the taxpayer’s hands;
- Income accrued; and
- The ITR schedule in which the income was offered.
Having signing authority does not necessarily mean that the balance in the company account is the director’s personal income. Reporting the account and determining ownership of its money are two separate questions.
The taxpayer should not treat the corporate bank balance as a personal asset unless the underlying facts support personal ownership. At the same time, signing authority should not be omitted merely because the money legally belongs to the company.
A Personal UAE Bank Account Requires Separate Reporting
A shareholder may also maintain a personal UAE bank account for salary, dividends or local expenditure.
That account may need to be reported as a foreign depository account. The information requested can include:
- Bank name and address;
- Account number;
- Account-opening date;
- Ownership status;
- Peak balance;
- Closing balance; and
- Gross interest credited.
A personal account that was open for only part of the calendar year may still require disclosure. Closing an account before the Indian financial year ends does not necessarily remove the reporting obligation where it existed at any time during the relevant calendar year.
A nil closing balance also does not eliminate the need to report an account that had a balance during the period.
Directorship and Unlisted-Share Disclosures
Indian income-tax returns may contain questions outside Schedule FA concerning:
- Directorships held during the relevant period; and
- Unlisted equity shares held at any time during the year.
An Indian resident who is a director of a UAE company should review these questions in addition to Schedule FA.
The information may include:
- Company name;
- Company type;
- Permanent Account Number, where available;
- Director identification details, where applicable;
- Whether the shares are listed or unlisted;
- Opening balance of shares;
- Shares acquired or transferred;
- Acquisition or sale consideration; and
- Closing balance.
A foreign company may not have an Indian PAN or an Indian Director Identification Number. The return’s current validation rules and instructions should be followed instead of entering an invented number merely to complete the field.
Schedule FA, the directorship disclosure and the unlisted-share disclosure serve different reporting purposes. Completion of one does not always replace the others.
Reporting Period: Calendar Year Versus Financial Year
One of the most common sources of error is the difference between the reporting period used for Schedule FA and the period used for income computation.
For Assessment Year 2026–27:
- Income is generally reported for the Indian financial year from 1 April 2025 to 31 March 2026; while
- Schedule FA generally captures foreign assets held during the calendar year ending 31 December 2025.
The notified return specifically refers to foreign assets held at any time during the calendar year ending 31 December 2025.
This difference can produce situations such as:
- A Dubai company incorporated in February 2026 may affect income reporting for the financial year but may not fall within the calendar-year asset period used in that year’s Schedule FA;
- A UAE bank account closed in December 2025 may still require disclosure even though it was not open on 31 March 2026; or
- Dividend income received between January and March 2026 may be included in the financial-year income schedules even though Schedule FA’s specified asset period ended on 31 December 2025.
The taxpayer should not prepare Schedule FA by simply copying balances from the financial year-end accounts.
Does a Dormant UAE Company Need to Be Reported?
A dormant company can still represent a foreign asset and financial interest.
Schedule FA reporting is not limited to profitable or actively trading companies. Disclosure may remain necessary even where the UAE company:
- Issued no invoices;
- Had no employees;
- Maintained no office;
- Had no bank transactions;
- Made a loss;
- Did not distribute a dividend; or
- Was under liquidation.
The shareholder should report the ownership interest according to the applicable form and maintain evidence explaining the company’s dormant or liquidation status.
If the company has been closed, the taxpayer should retain:
- Liquidation or deregistration certificate;
- Final financial statements;
- Evidence of share cancellation;
- Details of liquidation proceeds;
- Bank-account closure documents; and
- FEMA disinvestment reporting.
Is the UAE Company’s Profit Taxable Directly to the Shareholder?
A company and its shareholder are ordinarily separate taxable persons.
The UAE company’s retained profit does not automatically become the Indian shareholder’s personal income merely because the shareholder owns or controls the company. Personal taxation generally arises when the shareholder receives taxable salary, interest, dividends, directors’ fees, benefits or sale proceeds.
However, separate issues may arise where:
- The company is effectively managed from India;
- The company has an Indian permanent establishment;
- Personal expenses are paid by the company;
- Money is withdrawn without proper classification;
- Income belongs beneficially to the shareholder;
- Transactions lack commercial substance; or
- Anti-avoidance provisions apply.
Foreign-asset reporting should not be confused with determining the company’s residence or attributing its income. Schedule FA discloses the foreign interest; it does not independently decide that every company profit is the shareholder’s personal income.
Place of Effective Management
A UAE-incorporated company may be treated as an Indian tax resident if its place of effective management is in India during the relevant period.
The analysis examines where key management and commercial decisions necessary for conducting the business as a whole are actually made.
Risk factors may include:
- All strategic decisions being taken from India;
- UAE directors exercising no real authority;
- Contracts being negotiated and approved in India;
- Company banking being controlled from India;
- Core operations being performed by an Indian team;
- Board minutes not reflecting the actual process; and
- The UAE company having little or no operational substance.
If the company becomes resident in India, the consequences extend well beyond the shareholder’s Schedule FA. The company may have Indian return-filing, accounting and tax obligations on its worldwide income.
Nevertheless, the shareholder’s personal foreign-asset disclosure should still be separately reviewed.
Salary and Directors’ Fees
An Indian resident may receive salary or directors’ fees from a UAE company.
A resident and ordinarily resident individual is generally taxable in India on worldwide income, subject to the applicable law and treaty provisions. The remuneration should be reported under the correct income head based on the legal relationship and services performed.
Documents should include:
- Employment or service agreement;
- Board resolution;
- Payroll records;
- Evidence of duties performed;
- UAE payslips, where available;
- Bank statements;
- Details of benefits and allowances; and
- Tax documents.
A transfer to the owner’s personal account should not automatically be treated as salary. It could represent a dividend, loan, reimbursement, capital repayment or personal withdrawal. The legal and accounting characterization should be established before the Indian return is filed.
Dividends From a UAE Company
Dividends received from a UAE company may be taxable in India when the shareholder is resident and ordinarily resident.
The dividend may need to be reported:
- Under the appropriate income head;
- In Schedule FSI as foreign-source income;
- In Schedule FA as an amount paid or credited in relation to the foreign interest; and
- In Schedule TR where eligible foreign-tax relief is claimed.
The taxpayer should maintain:
- UAE company financial statements;
- Dividend declaration or resolution;
- Dividend voucher;
- Date of declaration and payment;
- Gross dividend amount;
- Bank credit evidence; and
- Details of foreign tax, if any.
The UAE currently does not generally impose withholding tax on ordinary outbound dividends. Consequently, a shareholder may have Indian tax on the dividend without any corresponding UAE withholding-tax credit.
UAE Corporate Tax paid by the company on its profits is generally the company’s tax. It should not automatically be claimed by the shareholder as foreign tax paid on the shareholder’s dividend.
Capital Gains on Sale of UAE Company Shares
An Indian resident selling shares or an ownership interest in a UAE company may be liable to Indian capital-gains tax.
The calculation may require:
- Date and cost of acquisition;
- Additional capital contributions;
- Sale agreement;
- Gross sale consideration;
- Transfer expenses;
- Holding period;
- Foreign-currency conversion;
- Applicable Indian tax rate;
- Treaty analysis; and
- Foreign tax paid on the transfer, if any.
The gross sale proceeds may also need to be reported in the relevant part of Schedule FA.
If the investment was made under the overseas-investment framework, the sale may additionally require FEMA reporting and repatriation of the proceeds through the designated Authorized Dealer bank.
Tax reporting and FEMA reporting are separate obligations. Compliance with one does not replace the other.
Schedule FSI
Schedule FSI reports income accruing or arising from sources outside India.
Foreign income should first be included under the correct head of income, such as:
- Salary;
- Income from house property;
- Business or profession;
- Capital gains; or
- Income from other sources.
It is then reported in Schedule FSI with the required country, taxpayer-identification, tax and treaty information.
The Income Tax Department’s guidance emphasizes that reporting income in Schedule FSI does not replace reporting it under the relevant head of total income.
For a UAE company owner, Schedule FSI may cover:
- Salary earned from the UAE company;
- Directors’ fees;
- Dividends;
- Interest on a shareholder loan;
- Royalty or service income;
- Capital gains on sale of shares; and
- Other taxable foreign receipts.
Schedule FA discloses the foreign asset or interest. Schedule FSI reports foreign-source income. Both may be required.
Schedule TR and Foreign Tax Credit
Schedule TR provides a country-wise summary of foreign-tax relief claimed in India. It draws from the information reported in Schedule FSI.
Where tax has been paid in the UAE on income that is also taxable in India, the individual should examine the foreign-tax-credit provisions and the India–UAE Double Taxation Avoidance Agreement.
The credit is generally limited to the lower of:
- Eligible foreign tax paid on the relevant income; or
- Indian tax attributable to that income.
The taxpayer should not claim the entire UAE tax paid by the company as personal foreign tax credit. The tax must ordinarily relate to the taxpayer and the same income offered in India.
Form 67
A taxpayer claiming foreign tax credit is required to furnish Form 67 electronically through the Income Tax Department portal. The Department’s Form 67 guidance confirms that the form is used where credit is claimed for tax paid in a foreign country or specified territory.
The taxpayer should retain:
- Foreign tax return;
- Tax payment receipt;
- Withholding certificate;
- Assessment or tax statement;
- Income reconciliation;
- Currency-conversion working;
- Proof that the tax has not been refunded; and
- Calculation of Indian tax attributable to the income.
The filing timeline and documentary requirements should be checked for the relevant tax year. A taxpayer should not wait until the Indian return is being finalized to request UAE records.
Information Exchange Makes Reconciliation Important
Foreign assets and income are increasingly visible to tax authorities through:
- Information exchanged under international arrangements;
- Common Reporting Standard data;
- Foreign bank and financial-institution reporting;
- Indian LRS and TCS records;
- RBI overseas-investment reporting;
- Annual Information Statements;
- Corporate registries;
- Banking due diligence; and
- Information obtained during assessments or investigations.
The amounts reported across the following records should therefore be reconciled:
- Schedule FA;
- Schedule FSI;
- Schedule TR;
- Form 67;
- Form FC and RBI filings;
- Annual Performance Reports;
- UAE company accounts;
- UAE Corporate Tax returns;
- UAE bank statements;
- Indian bank remittances;
- Form 26AS; and
- Annual Information Statement.
A difference is not necessarily an error, particularly where the forms use different reporting periods. However, the taxpayer should be able to explain the difference.
Consequences of Non-Disclosure
Failure to disclose a foreign asset can have consequences under the income-tax law and the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015.
Depending on the facts, consequences may include:
- Tax on an undisclosed foreign asset or income;
- Monetary penalties;
- Penalties for failure to furnish information;
- Interest;
- Extended assessment exposure;
- Prosecution in serious cases; and
- Difficulty explaining the source and ownership of the asset.
The Black Money Act contains fixed penalties for certain failures relating to foreign-asset returns and information. A statutory exception applies in specified cases where the aggregate value of foreign assets, other than immovable property, does not exceed the prescribed threshold, currently INR 20 lakh. The exception should not be treated as a general permission to omit foreign assets from Schedule FA.
The applicability of a penalty depends on the relevant section, the nature and value of the asset, the taxpayer’s residential status, the return filed and the surrounding facts.
Correcting an Earlier Omission
A taxpayer discovering that a UAE shareholding, bank account or signing authority was omitted should review the correction options immediately.
Depending on the timing and circumstances, the options may include:
- Filing a revised return within the permitted period;
- Filing an updated return where legally available and appropriate;
- Correcting Form 67;
- Responding to an Income Tax Department communication;
- Reconciling the asset in a pending assessment; or
- Seeking professional advice regarding exposure under the Black Money Act.
An updated return is not necessarily a complete solution for every foreign-asset omission. Its availability, additional tax cost and effect under other laws must be examined.
The taxpayer should prepare a complete factual file showing:
- When the asset was acquired;
- How it was funded;
- Whether FEMA reporting was completed;
- Income earned;
- Taxes paid;
- Returns previously filed; and
- Reason for the omission.
Practical Example
Assume an individual was resident and ordinarily resident in India during the relevant year and owned 100% of a Dubai free-zone company.
The individual:
- Invested AED 100,000 in the company;
- Served as its director;
- Operated its UAE corporate bank account;
- Maintained a separate personal UAE bank account;
- Received a salary from the company;
- Received no dividend; and
- Did not sell any shares.
The Indian return may require consideration of:
- The company shares under foreign equity and debt interests;
- The broader financial interest in the foreign entity;
- Directorship disclosure;
- Unlisted-share disclosure;
- Signing authority over the corporate bank account;
- The personal UAE bank account;
- Salary under the appropriate income head;
- Salary in Schedule FSI;
- Schedule TR and Form 67 if eligible UAE tax was paid; and
- POEM exposure if the company’s key decisions were made from India.
The fact that no dividend was declared does not eliminate the obligation to disclose the shareholding or accounts.
Documents UAE Company Owners Should Maintain
An Indian owner should preserve an annual foreign-asset file containing:
- UAE incorporation certificate;
- Trade license;
- Memorandum and articles of association;
- Share certificate or ownership register;
- Ultimate-beneficial-owner records;
- Share-subscription or purchase agreement;
- Proof of capital contribution;
- RBI Form FC and UIN details;
- Annual Performance Reports;
- UAE company financial statements;
- UAE Corporate Tax return;
- Personal and corporate bank statements;
- Bank signing-authority mandate;
- Salary agreement and payroll records;
- Dividend resolutions and vouchers;
- Loan agreements;
- Share-sale documents;
- Liquidation records;
- Foreign-tax certificates;
- Exchange-rate workings;
- Form 67;
- Schedule FA calculations; and
- Reconciliation with the Indian income-tax return.
These records should be prepared contemporaneously. Reconstructing peak balances, historical investment values and old exchange rates several years later can be difficult.
Common Reporting Mistakes
UAE company owners frequently make errors by:
- Assuming a UAE residence visa establishes Indian non-residence;
- Using ITR-1 despite owning a reportable foreign asset;
- Reporting the company only to the RBI but not in Schedule FA;
- Disclosing only income and omitting the underlying asset;
- Omitting a dormant or loss-making company;
- Ignoring a company incorporated at nominal value;
- Failing to report signing authority over the corporate account;
- Treating the corporate bank balance as personal income;
- Using the Indian financial year instead of the specified calendar year;
- Omitting directorship or unlisted-share disclosures;
- Reporting net rather than gross foreign income;
- Claiming the UAE company’s Corporate Tax as the shareholder’s foreign tax credit;
- Omitting salary because it was retained in the UAE;
- Ignoring shares held through a nominee or relative;
- Failing to report a closed account that existed during the relevant period;
- Using unsupported exchange rates;
- Not filing Form 67 when claiming foreign tax credit; or
- Assuming that no Indian tax payable means no disclosure is required.
Annual Compliance Checklist
Before filing the Indian return, a UAE company owner should confirm:
- Indian residential status for the relevant year;
- Correct ITR form;
- Relevant calendar year for Schedule FA;
- Legal and beneficial ownership of UAE shares;
- Acquisition date and investment cost;
- Peak and closing value;
- Dividends, salary, interest and other receipts;
- Sale or redemption proceeds;
- Personal UAE bank accounts;
- Signing authority over corporate accounts;
- Directorship details;
- Unlisted-share disclosures;
- Foreign-source income under the correct income head;
- Schedule FSI reporting;
- Schedule TR reporting;
- Form 67 and foreign-tax evidence;
- RBI overseas-investment filings;
- UAE company accounts;
- POEM and permanent-establishment exposure;
- Currency-conversion workings; and
- Consistency across all returns and regulatory filings.
Conclusion
Indian ownership of a UAE company creates reporting obligations that extend beyond incorporating the company and remitting capital under FEMA.
A resident and ordinarily resident taxpayer may need to disclose the UAE shareholding, financial interest, directorship, unlisted shares, personal foreign accounts and signing authority over the company’s bank account. Foreign salary, dividends, interest and capital gains may also require reporting under the appropriate income head, Schedule FSI and, where foreign tax credit is claimed, Schedule TR and Form 67.
The absence of dividends or taxable UAE income does not automatically remove Schedule FA reporting. Similarly, disclosure of the investment to the RBI does not replace disclosure in the Indian income-tax return.
The most reliable approach is to maintain an annual reconciliation between the UAE company records, foreign bank accounts, RBI filings and Indian tax return. Accurate reporting made on time is significantly easier to defend than an explanation prepared only after foreign-account information is matched with Indian tax records.
*******
Disclaimer
This article is intended solely for general educational and informational purposes. It does not constitute legal, tax, foreign-exchange, investment or professional advice. Income-tax forms, reporting periods, foreign-tax-credit procedures, monetary thresholds and official interpretations may change. The reporting position depends on the taxpayer’s residential status, legal and beneficial ownership, income, control and specific facts. Readers should examine the return form and law applicable to the relevant year and obtain professional advice before filing or correcting an Indian income-tax return.
References
- Income Tax Department, Step-by-Step Guide to Fill Schedules FSI, TR and FA:
https://www.incometax.gov.in/iec/foportal/sites/default/files/2026-03/Step%20by%20Step%20Guide%20FA%20FSI.pdf - Income Tax Department, Schedule FA Guidance:
https://www.incometax.gov.in/iec/foportal/nudge/nudge-schedule-fa - Income Tax Department, ITR-2 User Manual:
https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/file-itr-2-online/itr-2-UM - Central Board of Direct Taxes, notified income-tax return forms for Assessment Year 2026–27:
https://www.incometax.gov.in/iec/foportal/downloads/income-tax-returns - Income Tax Department, Form 67 Frequently Asked Questions:
https://www.incometax.gov.in/iec/foportal/help/statutory-forms/popular-form/form67-faq - Income-tax Act, 1961, applicable to periods governed by that legislation.
- Income-tax Act, 2025, as amended and applicable from 1 April 2026:
https://www.incometaxindia.gov.in/documents/d/guest/income_tax_act_2025_as_amended_by_fa_act_2026-pdf - Income-tax Rules, including the foreign-tax-credit provisions applicable to the relevant year.
- Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015:
https://www.incometaxindia.gov.in/Pages/acts/black-money-undisclosed-income-and-assets-and-imposition-of-tax-act.aspx - Foreign Exchange Management (Overseas Investment) Rules, 2022:
https://dea.gov.in/files/inline-documents/Foreign_Exchange_Management_Overseas_Investment_Rules_2022.pdf - Reserve Bank of India, Foreign Exchange Management (Overseas Investment) Regulations, 2022:
https://rbi.org.in/Scripts/NotificationUser.aspx?Id=12380&Mode=0 - India–UAE Double Taxation Avoidance Agreement:
https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx



