Union Budget 2026-27 - Finance Bill, 2026

The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 was enacted to address the issue of undisclosed foreign income and assets held by resident taxpayers. At the time of its introduction, a one-time compliance window was provided from 1 July 2015 to 30 September 2015 to enable voluntary declaration of undisclosed foreign assets acquired up to 31 March 2015, subject to payment of tax and penalty.

It has been observed that non-compliance is particularly prevalent in cases involving legacy or inadvertent non-disclosures for small taxpayers, including holdings arising from foreign employment benefits such as ESOPs or RSUs, dormant or low-value foreign bank accounts of former students, savings or insurance policies of returning non-residents, and assets held by individuals on overseas deputation. Further, information received under the Automatic Exchange of Information framework indicates non-disclosure of foreign financial assets by a significant number of PAN holders.

In order to facilitate voluntary compliance and enable resolution of such legacy cases of small taxpayers, it is proposed to introduce a time-bound scheme for declaration of foreign assets and foreign-sourced income, with payment of tax or fee based on the nature and source of acquisition and grant of limited immunity from penalty and prosecution under the Black Money Act in respect of matters covered by the declaration. Cases involving prosecution or proceeds of crime are proposed to be excluded The proposed scheme shall form part of the Finance Bill, 2026 and shall come into force from the date to be notified by the Central Government.

[Clauses 114 to 128]

 

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Full Text:

Union Budget 2026-27 - Finance Bill, 2026

Foreign asset disclosure scheme for small taxpayers offers a time-bound window with tax/fee and limited immunity. The proposed FAST-DS 2026 provides a time bound window for small taxpayers to declare undisclosed foreign assets and foreign sourced income, requires payment of tax or a fee based on nature and source of acquisition, and grants limited immunity from penalty and prosecution under the Black Money Act for matters covered by the declaration, while excluding cases involving prosecution or proceeds of crime; the scheme is included in the Finance Bill, 2026 (Clauses 114-128) and will commence from a date notified by the Central Government.