An Indian company with a small S.L. in Barcelona opens its annual filing calendar in October and finds the AD bank’s checklist already waiting. Half the items have Spanish names attached, and nobody knows whether the local accounts filed months earlier will do the job. Mostly, they will not, at least not as they stand.
The bank’s first question. Which entity and which investment? It wants the UIN linked to your Form FC, the Spanish company’s legal name and tax number, and your stake. If you hold the company through a holdco, the APR is filed for the direct foreign entity, not the operating company beneath it.
The document pack. Annual accounts (cuentas anuales), an audit report signed by an auditor on the official ROAC register, a shareholder register, share certificate evidence, remittance advices and the signed APR draft. Every document answers one reconciliation question: do what you report, what you remitted and what the company published all agree?
Spanish audit versus APR audit. Spain requires a statutory audit only above certain thresholds, so small companies can file abbreviated accounts. The RBI rule is separate: where the Indian investor controls the foreign entity, the APR needs audited statements, even if Spanish law does not. A locally exempt S.L. still needs an audit if you control it.
Where banks challenge numbers. Spanish filings are public, so a bank can compare your accounts with those deposited at the registry. Common causes of mismatch are draft accounts used for the APR while a later signed set was filed locally, or equity that does not agree with the Form FC.
Practical tips. Verify the auditor’s ROAC registration before signing the engagement letter, ask early whether the bank wants certified translations, and request the audited accounts in spring, not October.
Full guide with the document table and pre-submission checklist:
https://accorppartners.com/blogs/apr/apr-for-a-spanish-subsidiary-what-your-ad-bank-will-ask-for
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