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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.

✓ US CPA firm
✓ Audit under AICPA standards
✓ Report date agreed upfront
✓ US CPA firm
✓ Audit under AICPA standards
✓ Report date agreed upfront
✓ US CPA firm
✓ Audit under AICPA standards
✓ Report date agreed upfront

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?

Send your US trial balance and ownership details, and we will scope the audit and quote a fixed fee.

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

AuditReviewCompilation
What the CPA doesTests the numbers against evidenceAsks questions, runs analysisPuts your numbers into statements
Assurance givenReasonable assurance (an opinion)Limited assuranceNone
Accepted for the APRYesNoNo
Usable by your Indian auditor for consolidationYesWith extra workNo

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 usedSA 800, for the APR onlyAICPA auditing standards
Answer to the bank's host-country questionCannot confirmNot needed: it is a US audit
Usable with US banks, investors and buyersNoYes
Usable by your Indian auditorYesYes, 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

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
We test the numbers, confirm balances with your Indian company and the banks, and raise questions as we go.
Draft report review
You and your Indian auditor see the draft before anything is signed.
Final report and APR figures
The signed report, the audited statements and the APR mapping, on the agreed date.
Next year, planned

We fix next year’s dates now, so the audit starts early, not in November.

APR Audit FAQs

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.

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.

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.

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.

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.

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.

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.

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