Annual Report to Reserve Bank of India Due by September 30 Companies that grant equity compensation awards to employees of subsidiaries in India in reliance on the “general permission” (reflected in the exchange control regulations issued pursuant to the Foreign Exchange Management Act, 1999) must file an annual report with the Reserve Bank of India to provide information regarding stock plan transactions occurring during each financial year in India (April 1 to March 31). As part of the report (which must be submitted separately for each Indian subsidiary employing award recipients), companies must disclose:
• The number of shares issued to employees in India during the financial year,
• The number of Indian employees actually receiving such shares, and
• The amount of funds remitted out of India for the purchase of shares.
Although submission of the report is not subject to a specific deadline (it must be filed within a "reasonable time" following the end of the applicable financial year), companies generally should file the report by September 30.
For additional information about the reporting obligations in India or assistance in preparing the annual report to the Reserve Bank of India, please contact your GES attorney.
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