Reporting and tax on Indian funds, country by country
One table sets out the main form, threshold, deadline and penalty for holders in the USA, Canada, the UK, Germany, France, the Netherlands, Switzerland and the EU, with a short guide for each.
Prepared by Prem Tax and Accounting Corp. Last checked against official sources on November 5, 2026.
Where you live decides what you report on an Indian fund, and the rules differ more than most people expect. The table below sets eight places side by side, for tax year 2026 unless a row says otherwise. We prepare U.S. returns and work alongside your adviser in India, Canada or Europe; see our Indian CPA page.
The reporting matrix
| Place and guide | Filing | Trigger level | Due date | Penalty at a glance |
|---|---|---|---|---|
| USA, the fund | Form 8621 for each fund (the PFIC form), with Form 1040 | No floor. One exception: a fund with no election needs no form when there is no excess distribution or gain and all PFIC stock stays at USD 25,000 or less at the end of the year (USD 50,000 joint) | Due with the return on April 15, 2027, or October 15, 2027 under an extension | No dollar penalty; the tax year stays open until 3 years after filing |
| USA, the accounts | FBAR (FinCEN Form 114) and Form 8938 | FBAR: combined foreign accounts above USD 10,000 at any time. Form 8938, single and living in the U.S.: above USD 75,000 at any time or above USD 50,000 at year end | April 15, 2027, FBAR extended to October 15, 2027 automatically | FBAR, not willful: up to USD 16,536 per report (2025 table). FBAR, willful: up to 50% of the balance or USD 165,353, whichever is greater. Form 8938: USD 10,000 |
| Canada | Form T1135, plus TP-1079.8.BE-V for Quebec | Total cost of foreign property above CAD 100,000 at any point in the year | June 15 if self-employed; otherwise April 30, 2027 | CAD 25 per day, up to CAD 2,500; knowing failure CAD 500 per month, up to CAD 12,000 |
| UK | Self Assessment: SA106, plus SA108 when there are reporting-fund gains | A return is usually needed for foreign income or gains, unless the only item is dividends within the GBP 500 allowance | 2025-26: January 31, 2027. 2026-27: January 31, 2028 | GBP 100, then daily and percentage charges; offshore errors up to 150% |
| Germany | Anlage KAP-INV, Anlage KAP and a notice of foreign holdings | Any capital income left untaxed in Germany; the notice is due on a purchase or sale at a 10% stake or at total cost above EUR 150,000 (fund units not settled) | Tax year 2026: with an adviser, end of February 2028; without one, August 2, 2027 (July 31 falls on a Saturday) | Late surcharge of 0.25% for each month, capped at EUR 25,000; the notice carries a fine up to EUR 25,000 |
| France | Forms 2047, 2074 and 3916 | Every account abroad, no minimum (a folio held directly is not settled) | April 2027 is when the return for 2026 income opens | EUR 1,500 for each missing account; 80% on the extra tax; 10-year look-back unless balances stayed at EUR 50,000 or less |
| Netherlands | Income tax return, box 3 | In 2026, tax applies only above EUR 59,357 per person | Return for 2025: usually May 1, 2026 (extension on request) | Up to 100%, and 300% where box 3 income is concerned; look-back of 12 years |
| Switzerland | Cantonal return and securities list; Form DA-1 | All securities; DA-1 credit above CHF 100 of foreign tax | Zurich 2025 return: March 31, 2026 | Fine normally equal to the tax (one third to three times); back tax up to 10 years |
| EU | No holder form; sellers give a key information document | None for holders | None | Firms: the maximum fine is set at no less than EUR 5 million or 3% of turnover; holders face none EU-wide |
How to read the matrix
- The penalty column shows starting points or maximums, not what a person pays. FBAR is the U.S. report of foreign accounts, PFIC the U.S. label for most foreign funds, and a KID a key information document.
- Some points are not settled: whether an Indian scheme is a PFIC, how Canada classes it, whether a direct folio goes on French Form 3916, and whether a payout is a treaty dividend.
- Limits and penalty tables change yearly; see key dates and sources and updates.
- Indian funds report each reportable folio to India's tax department by May 31 each year; see EU rules and CRS reporting and treaties compared.
The country guides
USA
Indian mutual funds and the U.S. PFIC rules
How the U.S. PFIC rules treat Indian mutual funds: who files Form 8621, the $25,000 threshold and the excess distribution method, with an invented example.
Read →PFIC elections and other ways to hold India exposure
QEF, mark-to-market and purging elections in plain words for Indian mutual funds, with neutral alternatives and notes for new U.S. residents. Not advice.
Read →FBAR, Form 8938, the India treaty and tax credits
FBAR and Form 8938 for Indian mutual fund folios, plus the U.S.-India treaty, the foreign tax credit and Illinois, with thresholds, due dates and penalties.
Read →Canada
Canada: Form T1135, income, gains and the foreign tax credit
Canada has no PFIC rules. See when Form T1135 is due for Indian mutual funds, how income and gains are reported in dollars, and the foreign tax credit.
Read →Canada: offshore fund property, foreign trusts and registered plans
How Canada's offshore fund property rule, foreign trust rules, Forms T1141 and T1142 and registered plans apply to Indian mutual funds, with open issues.
Read →United Kingdom
Europe
Germany and Switzerland: how each taxes an Indian fund
How Germany taxes an Indian mutual fund (Vorabpauschale, partial exemption, Anlage KAP-INV) and how Switzerland treats it: tax-free gains, income, wealth tax.
Read →France and the Netherlands: tax on an Indian fund
How France taxes an Indian mutual fund (flat tax, Form 3916, penalties) and how the Netherlands does (box 3, actual-return claim), with 2025 and 2026 figures.
Read →Across countries
EU rules and CRS: why platforms skip Indian funds, and who sees your folio
Why European platforms do not sell Indian mutual funds (PRIIPs, KID, AIFMD, UK and Swiss rules) and how CRS and FATCA data on your Indian folio reaches home.
Read →India's tax treaties compared for Indian fund holders
Seven India tax treaties side by side: dividend caps, capital gains articles and home relief, plus what is unsettled for IDCW payouts and fund units.
Read →Common questions
Do all these countries ask for a special form?
No. The USA asks for several and Canada for Form T1135 above CAD 100,000 of foreign property. The UK, Germany, the Netherlands and Switzerland mostly use pages or lines of the ordinary return, France adds three forms, and the EU has no investor form.
Official sources
- IRS: Comparison of Form 8938 and FBAR requirements
- CRA: Questions and answers about Form T1135
- GOV.UK: Self Assessment deadlines
Keep reading
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