What to report on an Indian fund, place by place
One table shows the form, threshold, deadline and penalty headline for holders of Indian funds in the USA, Canada, the UK, Germany, France, the Netherlands, Switzerland and India, with a guide for each.
Prepared by Prem Tax and Accounting Corp. Last checked against official sources on November 5, 2026.
Our Eight-Flag Filing Grid puts the main duties of an Indian fund holder in one table, 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.
- Each row applies where the person lives, except India: an NRI's Indian return is filed there.
- A threshold only decides which form is filed, not what is taxed. Penalty headlines are ceilings or starting points.
- Not settled: PFIC status, Canada's class for an Indian fund, and French Form 3916 for a direct folio.
The table
| What a holder reports | Threshold | Deadline | Penalty headline | Guide |
|---|---|---|---|---|
| USA: Form 8621 per fund | No form if all PFIC units are USD 25,000 or less on December 31 (USD 50,000 joint) and there is no election, excess payout or gain | April 15, 2027 (October 15 if extended) | No set dollar penalty; the year stays open to the IRS for 3 years after filing | PFIC |
| USA: FBAR and Form 8938 | FBAR: foreign balances above USD 10,000 combined at any moment. Form 8938: above USD 50,000 on the year's last day, or USD 75,000 at any time (single, in the U.S.) | April 15, 2027; the FBAR extends to October 15 on its own | Form 8938: USD 10,000. FBAR (2025 table): up to USD 16,536 if not willful; a ceiling of the greater of USD 165,353 or 50% of the balance if willful | FBAR |
| Canada: Form T1135 | Cost of specified foreign property above CAD 100,000 at some point in the year | Due with the T1: April 30, 2027, or June 15 for the self-employed | Late: CAD 25 a day, up to CAD 2,500. Knowing: CAD 500 a month, up to CAD 12,000 | Canada |
| UK: SA106 and SA108 | Foreign income or gains usually mean a return | 2025-26: January 31, 2027 | GBP 100, then daily and percentage charges; offshore errors up to 150% | UK |
| Germany: Anlage KAP-INV and KAP | All capital income not taxed in Germany | August 2, 2027 without an adviser (July 31 is a Saturday) | 0.25% of tax a started month (minimum EUR 25), up to EUR 25,000 | Germany |
| France: Forms 2047, 2074 and 3916 | Every foreign account, no minimum | Return opens April 2027 | 80% surcharge on the extra tax; EUR 1,500 for each account not declared | France |
| Netherlands: box 3 | Box 3 tax starts above EUR 59,357 per person (2026) | Usually May 1, 2026 for the 2025 return | Fine up to 100% of the tax; for box 3 income, up to 300% | Dutch |
| Switzerland: securities list, Form DA-1 | All securities; DA-1 above CHF 100 of foreign tax | Zurich 2025 return: March 31, 2026 | Fine normally equal to the tax | Swiss |
| India: income tax return (ITR-2 if no business income) | Total income over the basic exemption limit, or a refund to claim | July 31, 2027 (tax year 2026-27) | Rs 5,000 late fee, or Rs 1,000 when income is Rs 5 lakh or less | India |
Source: IRS
Our checklist
The Eight-Flag Filing Grid:
- Mark each family member's place and the matching row.
- Note what each row measures: balance, value or cost.
- Calendar each deadline in that place's tax year.
Common questions
Why do the U.S. lines differ?
Each form measures something else, so a family can cross one line and not another.
Does India report my fund as well?
For reportable folios, yes: the fund house reports to India's tax department by May 31, and India shares it under FATCA or, where an exchange is active, CRS. See [EU rules and CRS reporting](/indian-mutual-funds/countries/eu-priips-and-crs/).
How often do these figures change?
Yearly, and some sooner. See [sources and updates](/indian-mutual-funds/tools/sources-and-updates/).
Official sources
- IRS: Comparison of Form 8938 and FBAR requirements
- IRS: Instructions for Form 8621 (Rev. December 2025)
- CRA: Questions and answers about Form T1135
- GOV.UK: Self Assessment deadlines
- Income Tax Department, India: Income tax returns FAQ
- Finance Act 2026, India (Gazette)
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