Employee Benefits Compliance

Private Gratuity Trust Registration

Set up an Income Tax-approved private gratuity trust to claim Section 36(1)(v) deductions, comply with AS 15 / Ind AS 19, manage off-balance-sheet employee liabilities, and protect employee gratuity entitlements. Includes actuarial valuation coordination and IT approval.

Section 36(1)(v)

Tax Deduction

₹20 Lakh per Employee

Max Tax-Exempt

30-45 Business Days

Timeline

₹14,999

Starting At

Commissioner of IT

IT Approval

AS 15 / Ind AS 19

Accounting

Overview

What is a Private Gratuity Trust?

A Private Gratuity Trust is a trust created by an employer to fund and manage the company's gratuity obligation to employees under the Payment of Gratuity Act, 1972. When approved by the Commissioner of Income Tax, contributions to this trust become deductible under Section 36(1)(v).

Gratuity is calculated as (15/26) x Last Salary x Years of Service. With average salaries rising, a company with 200+ employees can face a gratuity liability of ₹5-20 crore. A funded trust manages this systematically rather than as a sudden cash outflow.

Under AS 15 and Ind AS 19, the gratuity obligation must be actuarially valued and disclosed annually. The trust provides the funding structure required for proper accounting treatment and clean audit opinion on financial statements.

Section 36(1)(v) Deduction
Actuarial Valuation Required
AS 15 / Ind AS 19 Compliant
IT Commissioner Approval
Gratuity Formula

Gratuity Calculation

Gratuity = 15/26 × Last Salary × Years

Where Salary = Basic + Dearness Allowance

Max Tax-Exempt Amount₹20 Lakh per employee
Minimum Qualifying Service5 years continuous service
15/26 Factor15 days per year of service
Death / DisabilityPayable even below 5 years
Tax SectionSection 10(10) - Exempt
Deduction SectionSection 36(1)(v) - Trust contribution

Note: Without an approved trust, gratuity contributions are NOT deductible in the year of provision — only when actual payment is made.

Applicability

Who Should Set Up a Gratuity Trust?

Any employer with significant gratuity obligations benefits from a structured, IT-approved trust.

Companies with 10+ Employees

The Payment of Gratuity Act applies to all establishments employing 10 or more persons. Setting up an approved trust provides structured, tax-efficient compliance.

IT / Technology Companies

High-compensation tech companies with large workforces face significant gratuity obligations. An approved trust manages these liabilities efficiently while providing maximum tax benefit.

Manufacturing Companies with Long-Serving Staff

Manufacturing companies with blue-collar workers who often complete 5+ years of service face substantial gratuity payouts. A funded trust ensures these are met without cash flow disruption.

Listed Companies and Ind AS Filers

Ind AS 19 requires actuarial valuation and appropriate funding of defined benefit plans. A gratuity trust provides the funding structure required for Ind AS compliance.

PSUs and Government-Aided Organisations

Public sector undertakings and government-aided organisations must have approved gratuity trusts under their service rules and relevant ministry guidelines.

Companies Preparing for IPO or M&A

Investors and acquirers assess employee benefit obligations during due diligence. An approved, funded gratuity trust demonstrates proper governance of HR liabilities.

Key Benefits

Benefits of an Approved Gratuity Trust

Tax efficiency, accounting compliance, and employee protection in one structured framework.

Tax Deduction Under Section 36(1)(v)

Contributions made to an approved gratuity fund are deductible as a business expense under Section 36(1)(v). This converts what would be a cash outflow into a tax-efficient liability.

Off-Balance-Sheet Liability Management

Without a trust, gratuity is an unfunded liability on the balance sheet. With an approved trust, the liability is funded externally, improving the company's financial ratios and creditworthiness.

AS 15 / Ind AS 19 Compliance

Proper accounting treatment under AS 15 (Employee Benefits) and Ind AS 19 requires actuarial valuation of defined benefit obligations. A trust provides the funding mechanism for this.

Employee Benefit and Retention Tool

An approved gratuity trust demonstrates employer commitment to employee welfare. It reassures long-serving employees that their statutory entitlement is ring-fenced and secure.

Managed by Independent Trustees

Trust assets are managed separately from the company's operations by appointed trustees. This protects employee benefits even if the company faces financial difficulties.

Actuarial Valuation for Accurate Provisioning

Annual actuarial valuation (required under AS 15 / Ind AS 19) ensures the trust corpus is adequate to meet projected gratuity obligations, preventing funding shortfalls.

Maximum Tax Exemption ₹20 Lakh

Under the Payment of Gratuity Act, gratuity up to ₹20 lakh per employee is exempt from income tax. The trust structure ensures this exemption is properly administered.

Better Cash Flow Management

Regular contributions to the trust spread the gratuity cost over the service period rather than creating a large one-time cash outflow when senior employees retire or leave.

Our Process

Gratuity Trust Setup Process - Step by Step

From actuarial valuation to Income Tax approval — we manage the complete process.

01

Actuarial Valuation

Commission an actuarial valuation from a Fellow of the Institute of Actuaries of India (FIAI). The actuary calculates the Present Value of Obligation (PVO) using assumptions for salary growth, attrition, mortality, and discount rate.

02

Trust Deed Drafting

Draft the Trust Deed establishing the Private Gratuity Trust — specifying the settlor (company), trustees (at least two: one employer, one employee representative), beneficiaries, contribution provisions, investment norms, and administration rules.

03

Board Resolution

Pass a Board Resolution authorising: (1) establishment of the gratuity trust; (2) appointment of trustees; (3) initial contribution to the trust corpus; and (4) authorisation to apply for Income Tax approval.

04

Trust Registration

Register the Trust Deed with the Sub-Registrar of Assurances where the trust is situated. Pay stamp duty as applicable in the state. The registered Trust Deed is the foundational legal document.

05

Application for IT Approval

File an application before the Commissioner of Income Tax (Exemptions) under Section 2(5) of the Income Tax Act requesting approval of the gratuity trust as an ‘approved gratuity fund’.

06

IT Approval Hearing

Attend hearing before the Commissioner of Income Tax. Submit Trust Deed, actuarial valuation report, Board Resolution, and supporting documents. Respond to queries raised by the Income Tax authority.

07

Approval Order

Once satisfied, the Commissioner of Income Tax issues the approval order designating the trust as an ‘approved gratuity fund’. This enables Section 36(1)(v) deduction for contributions from the date of approval.

08

Annual Administration

Invest trust corpus as per IT Rules (IRDA-approved funds, government securities). Conduct annual actuarial valuation. Make annual contributions. Maintain trust accounts and file trust income tax return (ITR-7).

Documentation

Documents Required

The following documents are needed for trust deed registration and Income Tax approval application.

Trust Deed (duly registered)
Actuarial Valuation Report (FIAI certified)
List of Trustees with consent letters
Board Resolution establishing the trust
Certificate of Incorporation of the company
Employee register with salary and service details
Initial Contribution Cheque / Transfer to Trust
PAN Card of the Trust
Trust Bank Account Opening Documents
Previous gratuity fund balance (if transferring)

Starting at ₹14,999

Comprehensive fee for trust deed drafting, registration coordination, IT approval application, and first-year administration setup.

Trust Deed Drafting
Trustee Appointment Support
Actuarial Valuation Coordination
Trust Registration Coordination
IT Approval Application
IT Commissioner Hearing Support
PAN and Bank Account Opening
Annual Trust Account Setup

Timeline:

Trust Deed and Registration10-15 days
IT Approval Process20-30 days
Total30-45 business days
Set Up Gratuity Trust
FAQ

Frequently Asked Questions

Everything about private gratuity trust setup, IT approval, actuarial valuation, and AS 15 compliance.

Available Mon–Sat, 9 AM – 7 PM IST

Ready to Start Your Business Journey?

Let our Chartered Accountants handle your registrations, taxation and compliance while you focus on building your business.

✓ Free 30-min consultation✓ No hidden fees✓ Expert CAs & CSs✓ 100% digital process