APR Audit Services for Your Indian Company's US Subsidiary
Your RBI Annual Performance Report needs audited numbers from your US company. We audit it as a US CPA firm, so your bank and your Indian auditor can rely on the report.
APR audit services cover the independent audit of your US subsidiary’s financial statements, the audit your Annual Performance Report (APR) is built on. The RBI requires audited statements whenever your Indian company controls the foreign entity. CountSure, a US-based CPA firm, audits your US company under AICPA professional standards and issues the report your AD bank receives with the APR.
Here is where it usually goes wrong. The US company gets audited “for APR purposes only” by a firm in India. In December, the bank asks whether that auditor is allowed to audit a US company. The report cannot say yes, and the filing waits. If you also need help with the filing itself, see our APR filing services.
Need Audited US Numbers Before 31 December?
Does Your US Subsidiary Need an Audit for the APR?
Yes, if your Indian company controls it. Under Regulation 10(4) of the FEMA Overseas Investment Regulations, 2022, the APR must be based on audited financial statements. Unaudited statements are allowed only when the Indian investor has no control and the host country does not require an audit. US law generally does not require a private company audit, so the answer turns on control.
If You Own It Fully or Control It: Yes
A wholly owned subsidiary is controlled by definition. So is a joint venture where you appoint a majority of the board, or where your shareholding or a voting agreement gives you 10% or more of the voting rights. In each case, the audit of foreign subsidiary for APR is required, even though no US rule asks for one.
If You Hold a Small Passive Stake: Usually No
Without control, certified unaudited statements are enough, and you may not need us at all. A resident individual holding under 10% with no control and no other financial commitment does not file an APR. Our APR filing services page explains those cases.
If Your US Company Is Dormant: Still Yes
A US company with no revenue is not exempt from the APR. If you control it, its statements still need an audit. The audit is shorter, because there are fewer transactions to test, but it is not optional.
Why a Cheaper Review Report Won't Work for Your APR Filing
The APR asks for audited financial statements, and only an audit gives that. A review or a compilation costs less, but neither is an audit, whatever the bank’s checklist calls it.
What Your Bank Means by "Audited Financial Statements"
An audit means an independent auditor has tested your numbers against evidence and issued an opinion on them. A review gives limited assurance based mainly on questions and analysis. A compilation gives no assurance at all. Only the first meets the APR rule.
Audit, Review and Compilation, in Plain Terms
| Audit | Review | Compilation | |
|---|---|---|---|
| What the CPA does | Tests the numbers against evidence | Asks questions, runs analysis | Puts your numbers into statements |
| Assurance given | Reasonable assurance (an opinion) | Limited assurance | None |
| Accepted for the APR | Yes | No | No |
| Usable by your Indian auditor for consolidation | Yes | With extra work | No |
Who Should Audit Your US Subsidiary: Your Indian CA or a
US CPA Firm?
Who Should Audit Your US Subsidiary: Your Indian CA or a US CPA Firm?
Both routes exist. Only a US CPA firm gives you an audit carried out under the rules of the country where your company is registered.
Why AD Banks Increasingly Want a US CPA as Auditor
The APR rules require audited financial statements of your US subsidiary but do not name who must audit them. In practice, AD banks are increasingly insisting that the audit be done by an auditor licensed in the host country, and several have queried or held APRs supported only by an Indian CA’s audit. Some banks also ask the auditor to confirm they are permitted to audit the foreign entity under host-country rules, which an Indian CA cannot honestly confirm for a US company. A rejected or delayed APR can mean late submission fees and a hold on further overseas remittances.
Why a US CPA Audit Is the Safer Choice
An audit by a licensed US CPA firm meets what AD banks are asking for, so your APR goes through without that back and forth.Our audit and assurance services follow AICPA generally accepted auditing standards on US GAAP financial statements. You get one report that satisfies your APR in India and also works in the US when your subsidiary opens a credit line, raises money or is sold.
| Indian CA (special-purpose audit) | US CPA firm (CountSure) | |
|---|---|---|
| Standard used | SA 800, for the APR only | AICPA auditing standards |
| Answer to the bank's host-country question | Cannot confirm | Not needed: it is a US audit |
| Usable with US banks, investors and buyers | No | Yes |
| Usable by your Indian auditor | Yes | Yes, with a reporting package |
What We Check So Your APR Numbers Match Your Bank's Records
Your AD bank compares the APR with the remittances and records it already holds. We plan the audit around exactly those numbers, so the report and the bank’s file agree.
The Money You Sent From India
We tie the US company's capital to every overseas investment remittance, by UIN, and to the share certificates or LLC membership records on the bank's file. Say you sent $200,000 as equity, but the books show $120,000 as capital and $80,000 as a loan. We find that before the bank does.
Loans and Payments Between Your Indian and US Companies
We confirm balances with your Indian company and match them to what the US company reports on Form 5472, the IRS form for transactions with a foreign owner. Loans, service fees and royalties then agree across the audit, the US return and the APR.
Profits and Dividends Sent Back to India
We test revenue, expenses and year-end cut-off on the US GAAP financial statements, and trace any dividend or repatriation to bank evidence. Figures on the US tax return are not copied across, because tax-basis and audited numbers differ.
Any Companies Your US Subsidiary Owns
If your US company set up, bought or closed a company of its own during the year, the APR reports it. We confirm those changes and the ownership percentages before the report is signed.
Your Indian Auditor Will Need These Numbers Too
One audit that serves your APR and your Indian company’s consolidated accounts. Tell us your year-end to get started.
One APR Audit That Also Works for Your Indian Auditor
Your Indian statutory auditor consolidates the US company into your group accounts, under Ind AS 110 or AS 21. To do that, they rely on our work as the other auditor, under SA 600. We give them what they need in the format they use.
What Your Indian Auditor Needs From the US Side
- The signed audit report and audited statements, issued in time for their own deadline.
- A group reporting package with balances, related-party items and subsequent events.
- A schedule of differences between US GAAP and Indian accounting standards, where your group reports under Ind AS.
- Direct answers to their questions, so nothing has to be routed through you.
Turning US Dollar Numbers Into the APR's Rupee Figures
The audit is in US dollars. We map every APR figure to the audited statements and show the rupee conversion your bank’s format asks for, so nobody has to rebuild the numbers in December.
What You Get With Our APR Audit Services
on your US subsidiary, signed by a licensed CPA.
with the balance sheet, income statement, cash flow statement and notes.
every APR figure linked to the audited statements, with rupee conversions.
ODI remittances by UIN matched to capital and loans.
for your Indian statutory auditor.
listing anything in the books to fix before next year.
Where your filing also needs an Indian CA’s certificate or the bank submission itself, Indian chartered accountants handle that part, as and when required, and we work with them directly.
Why Indian Companies Trust CountSure to Audit Their US Subsidiary
01
A US CPA firm, auditing to US standards
Our audits are performed under AICPA professional standards, and a licensed CPA oversees and signs off every engagement.
02
We read both sides
We plan the audit around FEMA's APR rules and US GAAP, so the report fits the bank's file and your Indian auditor's needs.
03
Deadlines met
The report date is agreed at the start, working back from your 31 December APR date and your Indian auditor's timetable, and we hold to it.
04
A fixed fee, set per company
Every US company is different, so we quote after seeing your books, and the fee is agreed before work starts.
How Our APR Audit Works, Step by Step
A quick call
We check whether you need an audit at all, and confirm your US year-end, ownership and deadline.
A short document list
You get one list, based on your company, not a generic checklist.
The audit work
Draft report review
Final report and APR figures
Next year, planned
We fix next year’s dates now, so the audit starts early, not in November.
APR Audit FAQs
Is an audit compulsory for the APR?
Yes, if your Indian company controls the foreign entity. The APR must be based on audited financial statements unless you have no control and the host country does not require an audit. A wholly owned US subsidiary always needs one.
Can my Indian CA audit my US company for the APR?
Yes, usually as a special-purpose audit for the APR only. The catch is that some AD banks ask the auditor to confirm they may audit under host-country rules, which an Indian CA cannot do for a US company. A US CPA audit avoids that question and can also be used in the US.
Will my bank accept an audit report from a US CPA firm?
Yes. The APR must be based on the audited financial statements of the foreign entity, and a US company is audited under US standards by a US CPA firm. That is the host-country audit the rules have in mind.
My US company had no business this year. Does it still need an audit?
Yes, if you control it. A dormant company is not exempt from the APR, so its statements still need an audit. With few transactions, the audit is shorter and simpler.
Is a review report enough for the APR?
No. A review gives limited assurance and is not an audit. The APR rule asks for audited financial statements, so a review report will not meet it.
How long does an APR audit take?
It depends on the size of the company and the state of its books. We agree the report date at the start, working back from your 31 December APR deadline and your Indian auditor’s timetable, and we meet it.
Can the same audit be used for my Indian company's consolidated accounts?
Yes. Your Indian statutory auditor can rely on our audit when consolidating the US company. We provide a reporting package and answer their questions directly.
Get Your US Audit Done Before the APR Deadline
Send your US subsidiary’s trial balance and year-end, and we will confirm the scope, the report date and a fixed fee.
