RSU Vesting and Sale in Different Currencies: Perquisite, FX and Capital-Gains Working
By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026
2-minute summary
- RSUs commonly create two separate tax events: salary/perquisite taxation at vesting or another prescribed employee-tax point, and capital gains when the shares are later sold. When vest and sale occur in different currencies or on different dates, the rupee values must be computed separately using the exchange-rate rule applicable to each event.
- Do not calculate capital gain as sale proceeds minus zero merely because the employee paid no cash for the RSUs. The perquisite value already taxed under the employee-compensation rules is a key cost-basis input under the applicable law. Broker fees, withholding and share-withholding-for-tax should also be reconciled to the actual number of shares received and sold.
- Foreign RSUs may require resident foreign-asset/FSI reporting and foreign tax credit. For legacy AY 2026-27 use the old Act ITR-2/FSI/TR/FA and Form 67 where applicable; for Tax Year 2026-27, the Income Tax Act, 2025 and Form 44 framework applies.
Current position
Control and evidence map
| # | Control / evidence requirement |
|---|---|
| 1 | Obtain the vest statement showing units vested, shares withheld and FMV/payroll value. |
| 2 | Reconcile the perquisite amount appearing in payroll/Form 16 or the current-law salary statement. |
| 3 | Maintain a lot-wise INR cost basis for every vest date rather than one blended foreign-currency number. |
| 4 | Translate sale proceeds/fees under the applicable capital-gains exchange-rate rule and match broker confirmations. |
| 5 | Complete foreign-asset/income and FTC schedules/forms based on residential status and the governing Act. |
Worked example
An employee vests 100 US-company RSUs when the share price is USD 50; 30 shares are withheld for payroll taxes. Months later the employee sells 70 shares at USD 65. The Indian file should preserve the rupee perquisite value at vest, treat that taxed value as the relevant starting cost under the applicable rule, separately translate the sale transaction and reconcile any foreign withholding. Simply reporting USD 4,550 sale proceeds as pure gain would overstate income.
Common mistakes
- Using zero cost for RSUs because no exercise price was paid.
- Applying one FX rate to both vest and sale events.
- Ignoring shares withheld for payroll taxes when reconciling quantities.
- Claiming foreign tax credit without the required form and evidence.
Frequently asked questions
Are RSUs taxed only when sold?
Typically no. Employee-compensation taxation can arise earlier, with a separate capital-gains event on sale.
Can I use the broker’s gain report directly?
Not without checking Indian tax cost and FX rules.
What changes in 2026?
The governing Act/form set changes for Tax Year 2026-27, while AY 2026-27 remains a legacy return.
Official sources
- Income Tax Department - ITR-2 Online User Manual - Schedule FSI, TR and FA (ITR-2; AY 2026-27 portal guidance)
- Central Board of Direct Taxes - Form 44 - Foreign income and Foreign Tax Credit under Income Tax Act, 2025 (Form 44 / rule 76(10); 2026-03-20)
- Income Tax Department - Income Tax Act, 2025 - official transition and guidance hub (Income-tax Act, 2025; effective 2026-04-01)
Disclaimer
Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.