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FOREIGN LIABILITY AND ASSETS RETURN (FLA RETURN)

The Reserve Bank of India (RBI) have extended the last date of submission of FLA
Returns for the Year 2021 to July 31, 2021.

With that said, let’s discuss the FLA Return first:

Introduction:

With day by day increase in foreign investments, in India and outside India, the importance
of Foreign Exchange Management Act (FEMA) and its Regulations has been increased by
many folds. For regulating and tracking of such transactions, FEMA has enumerated certain
filing compliances on the Party(ies) resident in India. One of such is filing of Foreign
Liabilities and Assets Return also known as FLA Return.

Filing Requirements:

The Companies / LLPs who have made Overseas Direct Investment (ODI) abroad and / or
received Foreign Direct Investment (FDI) in any financial year are required to submit FLA
Return to the RBI. The FEMA regulations also require Partnership firms to file the FLA
Return if they have made ODI and / or received FDI. The Partnership firms need to send
mail at surveyfla@rbi.org.in to get a dummy CIN number which will enable them to file FLA
Return. If the Partnership firm has already got the dummy CIN number, then they should
use the same CIN number.

Assets and Liabilities as on March 31 shall be considered.

Mandatory Registration:

Since, the FLA Return is to filed online, the Entity filing the same needs to first get registered
on the RBI filing portal as the First Time User. On opening the portal, one can find drafts of
Authority Letter and Verification Letter which is to be signed and uploaded while making
the registration. After successful registration, one can start filing of FLA Return.

Due Date:

The Entities are required to file the FLA Return based in audited / unaudited accounts by
July 15, every year.

If the Entity’s Accounts are not audited before the due date of submission, then the FLA
Return should be filed based on unaudited / provisional accounts. Although, the entities are
supposed to submit the revised FLA Return based on the Audited Accounts by September
30.

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