EquatePlus RSU India Tax Filing — Complete ITR-2 Guide (FY 2025-26)

EquatePlus is the equity plan platform used by SAP, Deutsche Bank, Siemens, and several other large European multinationals. If your employer grants RSUs through EquatePlus and you are a resident in India, your filing involves one complication that most other broker guides skip entirely: the currency is EUR, not USD. The SBI TT rates for EUR behave differently, the statement format is different, and the tax software import paths are different. This guide covers everything specific to EquatePlus — with actual rupee calculations.

Understanding the EquatePlus Transaction Report

EquatePlus provides a Transaction Report that lists every equity event — vesting, sale, dividend — in chronological order. To download it: log in to equateplus.com → Reports → Transaction Report → select date range → Export.

The report includes:

• Transaction type: Vest, Sale, Dividend, Tax Withholding
• Date: Transaction date
• Quantity: Number of shares
• Price: Per-share price in EUR (or the company's listing currency)
• Total value: Gross amount in EUR
• Net proceeds: After any sell-to-cover withholding

The EUR Currency Problem — Why This Is Different

Most RSU guides written for Indian residents focus on USD because Fidelity, Schwab, and Morgan Stanley all deal in USD. EquatePlus is different — and EUR creates two specific complications.

1. SBI TT EUR Rates Are Less Discussed

The SBI publishes TT rates for EUR just as it does for USD, but most filers and even some CAs are unaware of where to find historical EUR rates. Rule 115 applies identically — you need the EUR TT Buy rate on the last working day of the month preceding the transaction month. The EUR rate is not the same as dividing the USD rate by the EUR/USD exchange rate. It is a directly published SBI rate.

2. EUR/INR Fluctuates Differently

EUR/INR moves on European Central Bank decisions, not US Fed policy. In some years the EUR/INR rate has moved 8–10% over a financial year. This means the INR value of the same EUR holding can vary significantly depending on which month the vest or sale occurred — and getting the Rule 115 date wrong by even one month can shift the declared gain materially.

Perquisite Tax at Vesting

When your RSUs vest, the fair market value (FMV) of the shares on the vest date is taxable as salary perquisite under Section 17(2) of the Income Tax Act. Your Indian employer deducts TDS on this and reports it in Form 16.

For EquatePlus — where shares are listed in EUR — the FMV in INR is computed using the Rule 115 EUR TT Buy rate.

Capital Gains Calculation — Rule 115 SBI TT Rate for EUR

Rate Reference by Transaction Type

Transaction	Rate Date	Example (April vest)
Vest — cost of acquisition	Last WD of prior month	Vest April 1 → rate on March 31
Sale proceeds	Last WD of prior month	Sale September 15 → rate on August 29
Schedule FA A3 initial value	Last WD of month before first vest in CY	First vest in April → rate on March 31
Schedule FA A3 peak value	Date of highest closing price in calendar year	Highest price day between Jan 1–Dec 31
Schedule FA A3 closing value	Last WD of December	Rate on December 31 (or last trading day)

Capital Gains Formula

STCG vs LTCG — Holding Period Rules

The 24-month holding period for LTCG qualification starts from the vest date, not the grant date. RSU grants typically have a 3–4 year vesting schedule, so older tranches may qualify as LTCG even if they feel recent.

Holding Period (from Vest Date)	Classification	Tax Rate
Less than 24 months	Short-Term Capital Gain	Slab rate
24 months or more	Long-Term Capital Gain	12.5% without indexation (Section 112A, Finance Act 2024)

Sell-to-Cover Treatment

When RSUs vest through EquatePlus, the platform typically sells a portion of shares to cover the Indian TDS liability. This sell-to-cover transaction appears in your Transaction Report as a "Sale" on the vest date or very shortly after.

These shares are a capital gains event. The gain is the difference between the sell-to-cover price and the vest-date FMV — both converted to INR at their respective Rule 115 rates. Since the sale usually happens on the vest date itself, both rates are typically the same, making the gain minimal but still reportable.

Schedule FA — A2 and A3 for Your EquatePlus Account

Schedule FA disclosure runs on the calendar year — January 1 to December 31, not the Indian financial year. If you held shares in your EquatePlus account at any point between January and December, disclosure is mandatory.

Table A2 — Foreign Custodial Account

Your EquatePlus account is a foreign custodial account. A2 requires:

• Country: Germany (for SAP) or the country of the EquatePlus entity managing the plan
• Name of financial institution: EquatePlus AG (or the specific entity name in your plan documents)
• Account number: Your EquatePlus participant ID
• Peak balance during calendar year: Highest value of shares held at any point in Jan–Dec, in INR at the EUR TT rate on that date
• Closing balance as of 31 December: Shares held × closing price × EUR TT rate on December 31
• Gross interest credited: Usually nil for equity plan accounts

Table A3 — Foreign Equity Holdings

One entry per company whose shares you held in the calendar year:

• Name of entity: SAP SE (or your employer's full legal name)
• Country: Germany (or country of incorporation)
• Date of acquisition: Earliest vest date for this holding
• Initial value: Shares × FMV at first vest × EUR TT rate on applicable Rule 115 date
• Peak value: Highest closing price during Jan–Dec × shares held on that date × EUR TT rate on that date
• Closing value: Shares × closing price on December 31 × EUR TT rate on last working day of December

Dividend Income and Form 67

SAP SE and other European companies listed on German or other European exchanges pay dividends in EUR. These dividends may be subject to withholding tax in the country of the company's incorporation before reaching your EquatePlus account.

For German-listed shares, Germany withholds Kapitalertragsteuer (capital gains tax) at 25% plus solidarity surcharge, for a total of approximately 26.375%. Under the India-Germany DTAA, the maximum withholding on dividends is 10% for individual shareholders.

If the actual withholding exceeds the DTAA rate, you can claim a refund from the German tax authority. The Indian tax credit (Form 67) covers only up to the DTAA-permitted rate — the excess is recoverable from Germany, not India.

Filing ITR-2 — Where Each Figure Goes

Income / Disclosure	Schedule in ITR-2	Notes
Perquisite at vesting	Schedule S (Salary)	Should match Form 16; verify employer has included it
Capital gains on RSU sale	Schedule CG	Separate entries for STCG and LTCG; lot by lot
Sell-to-cover gains	Schedule CG	Usually STCG; small amounts but mandatory
Dividend income	Schedule OS → Foreign Source Income	Gross dividend before withholding, in INR
Schedule FA disclosure	Schedule FA → A2, A3	Calendar year Jan–Dec; not the Indian FY
Foreign tax credit	Schedule TR + Form 67	File Form 67 before ITR; then reference in TR

Six Errors Specific to EquatePlus Filers

1. Using USD TT Rate Instead of EUR TT Rate

EquatePlus transactions are in EUR. The Rule 115 rate to use is the SBI EUR TT Buying rate — not the USD rate, and not a cross-calculation. The SBI publishes EUR TT rates daily alongside USD rates.

2. Converting EUR to USD First, Then to INR

Some filers use market EUR/USD rates to convert to USD, then apply SBI USD TT rates. This is incorrect under Rule 115 and constitutes misreporting under Section 270A.

3. Skipping Schedule FA Because Shares Were "Just Held, Not Sold"

Schedule FA disclosure is triggered by holding, not by income or sale. Vested-but-unsold shares sitting in your EquatePlus account all year require full A2 and A3 disclosure for that calendar year.

4. Using Grant Date as Holding Period Start

The 24-month LTCG holding period starts from the vest date. SAP typically grants RSUs 3–4 years before they vest — using the grant date would incorrectly classify many short-term gains as long-term.

5. Missing Sell-to-Cover in Schedule CG

The sell-to-cover transaction is a capital gains event. It appears in the EquatePlus Transaction Report as a "Sale" entry on vest day. It is commonly omitted from ITR-2 because filers assume it is covered by the perquisite TDS. It is not.

6. Wrong DTAA Article for German Dividend Withholding

For dividends from German-listed shares, the applicable DTAA is India-Germany, Article 10. Some filers incorrectly reference the India-US DTAA or cite no article at all in Form 67, causing the credit to be disallowed during scrutiny.

How GainSutra Handles EquatePlus Statements

GainSutra has a dedicated parser for EquatePlus Transaction Reports. The tool auto-detects EquatePlus statements on upload and defaults to EUR currency — no manual selection needed.

For each transaction it:

• Identifies vest events, sale events, and dividend payments from the Transaction Report
• Applies the correct SBI EUR TT Buy rate per Rule 115 to each transaction — from a database covering 2001 to present
• Classifies each lot as STCG or LTCG based on the vest-to-sale holding period
• Computes Schedule FA A2 peak balance and A3 peak value using a live stock price database for the full Jan–Dec window
• Generates Form 67 data for dividend withholding including the India-Germany DTAA article reference
• Exports Excel workings and software-ready import files for Computax, Genius, ClearTax, and TaxBuddy

Everything runs in your browser. No PDF, no financial data, no client information leaves your device.

Summary

• EquatePlus transactions are in EUR — use SBI EUR TT Buy rates, not USD rates
• Rule 115: last working day of the month before the transaction month
• Never convert EUR→USD→INR; use the direct SBI EUR TT rate
• Perquisite at vesting is salary income; cost of acquisition equals this FMV in INR
• Holding period starts from vest date; 24 months for LTCG at 12.5%
• Sell-to-cover is a separate STCG event — report it in Schedule CG
• Schedule FA A2 and A3 mandatory for any calendar year you held shares
• German dividend withholding: India-Germany DTAA Article 10; file Form 67 before ITR
• Non-disclosure penalty: ₹10 lakh per asset under Section 41, Black Money Act 2015

© 2026 GainSutra · gainsutra.com · Built by CAs, for CAs