Country-by-Country Reporting (International Group Report) under the Income Tax Act 2025

Country-by-country reporting is the annual report of a multinational group's revenue, profit, tax and headcount in every country where it operates. Under the Income-tax Act, 2025 it sits in section 511 ("Furnishing of report in respect of international group"). A parent entity or alternate reporting entity resident in India files the report within 12 months of the end of the reporting accounting year, in Form No. 59. A group whose consolidated revenue for the preceding year does not exceed Rs 6,400 crore is outside the section (rule 124(7)).

This guide explains who has to do what, the forms and dates in the Income-tax Rules, 2026, and the penalties in section 459. It also covers the related master-file style record under section 171 and rule 123, because the two are often confused. Figures are from the Act as amended by the Finance Act, 2026, and the Rules. Last reviewed against that text on 10 November 2026.

What is an international group report under section 511?

Section 511(3) says the report must contain, for each country or territory where the group operates:

• revenue, profit or loss before income-tax, income-tax paid, income-tax accrued, stated capital, accumulated earnings, number of employees and tangible assets (other than cash or cash equivalents);
• the details of each constituent entity, including where it is incorporated and where it is resident;
• the nature and details of each entity's main business activity; and
• any other information that is prescribed.

The aim is to let the tax authority see where a group books its profits, tax and people, so that it can test whether profit is shifted to low-tax countries.

Which terms matter in section 511?

Section 511(10) defines the vocabulary. In plain language:

Term	Meaning in short
International group	A group with two or more enterprises resident in different countries, or an enterprise that does business through a permanent establishment in another country (511(10)(g))
Parent entity	A constituent entity that holds an interest in other group entities and must prepare consolidated financial statements (or would have to, if its shares were listed), and is not itself consolidated into another entity's statements (511(10)(h))
Constituent entity	A separate entity included in the consolidated statements (or that could be if shares were listed), an entity left out only for size or materiality, or a permanent establishment that prepares its own financial statement (511(10)(d))
Alternate reporting entity	A constituent entity the group designates, in place of the parent, to file the report in the country where that entity is resident (511(10)(c))
Accounting year	The tax year if the parent is resident in India; otherwise the annual period for which the parent prepares financial statements in its own country (511(10)(a))
Systemic failure	A country that has an exchange agreement with India but has suspended automatic exchange, or has persistently failed to send India the reports it holds (511(10)(l))

Who has to file what? A quick decision tree

What must an Indian subsidiary of a foreign group do?

Section 511(1) applies to every resident constituent entity of an international group whose parent is not resident in India. It must notify the prescribed authority:

• whether it is itself the alternate reporting entity; or
• the details of the parent entity or alternate reporting entity, and the country or territory where they are resident.

Rule 124(2) fixes the form and timing: Form No. 58, two months before the due date of the report under section 511(2). The authority is a Joint Director designated by the Director General of Income-tax (Systems) (rule 124(1)).

When must an Indian entity file the report itself?

Section 511(4) makes a resident constituent entity (other than the parent or alternate reporting entity in India) file the report if the parent is resident in a country or territory:

• where the parent is not obliged to file such a report; or
• with which India does not have the required agreement for exchange of the report (a tax treaty under section 159(1) or (2) plus a notified agreement for exchanging the report, section 511(10)(b)); or
• where there has been a systemic failure that the Indian authority has intimated to the constituent entity.

The time is 12 months from the end of the reporting accounting year (rule 124(4)). For a systemic failure, it is six months from the end of the month in which the failure was intimated (rule 124(5)).

If the group has more than one Indian entity, any one may file for all of them, provided the group designated it and told the authority in writing. Rule 124(6) says this designation is conveyed in Form No. 60 (section 511(5)).

When does the Indian entity not have to file under section 511(4)?

Section 511(6) switches off sub-sections (4) and (5) where the group's alternate reporting entity has already filed the report in its own country on or before that country's due date, and all of these are true:

1. the report is required under that country's law;
2. that country has an exchange agreement with India;
3. the Indian authority has not conveyed a systemic failure for that country to any Indian constituent entity;
4. that country has been informed in writing that the entity is the alternate reporting entity for the group; and
5. the Indian authority has been informed under section 511(1).

What is the revenue threshold for country-by-country reporting?

Section 511(8) excludes a group for an accounting year if the total consolidated group revenue, from the consolidated financial statement of the preceding accounting year, does not exceed the prescribed amount. Rule 124(7) prescribes Rs 6,400 crore. If the revenue is in a foreign currency, rule 124(8) converts it at the telegraphic transfer buying rate on the last day of that preceding accounting year.

Worked example 1: does the group cross the threshold?

Assumptions: the parent is in a foreign country and the group's accounting year runs to 31 December. Revenue for the preceding year was USD 700 million. The telegraphic transfer buying rate on 31 December of that year was Rs 83 (an assumed figure for illustration).

Step	Working	Result
1. Convert revenue	USD 700,000,000 x Rs 83	Rs 58,10,00,00,000 (Rs 5,810 crore)
2. Compare with limit	Rs 5,810 crore vs Rs 6,400 crore	Below the limit
3. Result	Does not exceed Rs 6,400 crore	Section 511 does not apply for the year

Worked example 2: the same group a year later

Revenue for the next preceding year is USD 800 million and the rate on the last day is Rs 84 (assumed).

Step	Working	Result
1. Convert revenue	USD 800,000,000 x Rs 84	Rs 67,20,00,00,000 (Rs 6,720 crore)
2. Compare with limit	Rs 6,720 crore vs Rs 6,400 crore	Above the limit by Rs 320 crore
3. Result	Exceeds Rs 6,400 crore	Section 511 applies, so the Indian entity must notify (Form 58) and, if section 511(4) applies, file

Is there still a Form 3CEAA for the country-by-country report?

Many people still search by the old 3CEA-series form numbers. Those forms were prescribed under the repealed 1961 Act. Under the Income-tax Rules, 2026 the country-by-country forms are numbered 58, 59 and 60 (rule 124), and the master-file style forms are 56 and 57 (rule 123). Use the 2026 numbers on any filing for tax year 2026-27 onwards. Check the official forms on the income-tax portal for the current formats, since this article does not reproduce them.

What are the due dates?

Action	Who	Form	Due date	Source
Notification of parent or alternate reporting entity	Indian constituent entity of a foreign-parented group	58	Two months before the report due date	s.511(1), r.124(2)
Report	Indian parent or alternate reporting entity	59	12 months from the end of the reporting accounting year	s.511(2), r.124(3)
Report by Indian constituent entity	Entity covered by s.511(4)	As prescribed	12 months from the end of the reporting accounting year	r.124(4)
Same, on systemic failure	Entity covered by s.511(4)(c)	As prescribed	6 months from the end of the month of intimation	r.124(5)
Designation of one Indian entity	Group	60	Conveyed in writing as per s.511(5)	r.124(6)
Reply to a notice on accuracy	Reporting entity	-	30 days from receipt, extendable by up to 30 more days	s.511(7)

Real-life example 1: an Indian parent

Meena runs finance for an Indian listed manufacturer with subsidiaries in four countries. It is the parent entity and prepares consolidated financial statements. Because the parent is resident in India, the accounting year is the tax year, so for tax year 2026-27 (ended 31 March 2027) the report in Form 59 is due within 12 months, that is by 31 March 2028 (section 511(2), section 511(10)(a)(i)). The group would have notified under rule 124(2) only if it were the Indian entity of a foreign-parented group, which it is not. It checks first that preceding-year consolidated revenue exceeds Rs 6,400 crore, otherwise it is outside the section.

Real-life example 2: an Indian subsidiary of a foreign parent

Ravi is the CFO of an Indian company owned by a foreign group. The parent's country has the exchange agreement with India and the parent files there, so Ravi's company notifies under section 511(1), in Form 58, who the parent is and where it is resident, two months before the report due date. Later, India tells the company that there has been a systemic failure for that country. The company now falls under section 511(4)(c) and must file the report itself, within six months from the end of the month in which the failure was intimated (rule 124(5)).

What is the difference between this report and the Form 56 record?

Section 171 and rule 123 impose a separate duty. A constituent entity of an international group must keep information and documents about the group (entity list, ownership chart, business description, intangibles, financing, consolidated financial statement and unilateral APAs) if both of these hold:

• consolidated group revenue for the accounting year exceeds Rs 500 crore; and
• the aggregate value of international transactions exceeds Rs 50 crore, or transactions in intangible property exceed Rs 10 crore (rule 123(1)).

This is furnished to the Joint Director in Form No. 56 by the due date of the return of income under section 263(1)(c) (rule 123(2)). Part A of Form 56 must be filed even if the limits are not crossed (rule 123(3)). Records are kept for nine years from the end of the relevant tax year (rule 123(5)). One entity may file for several if designated, with Form No. 57 sent 30 days before the Form 56 due date (rule 123(4)).

	Section 511 report	Rule 123 record
Content	Country-wise revenue, profit, tax, employees, assets	Group structure, business, intangibles, financing documents
Revenue limit	Consolidated revenue above Rs 6,400 crore	Above Rs 500 crore, plus transaction limits
Form	58 (notice), 59 (report), 60 (designation)	56 (record), 57 (designation)
Timing	12 months from the end of the accounting year	Due date of the return of income

What if the tax authority questions the report?

Under section 511(7), the authority may issue a written notice asking the entity to produce information and documents to test the accuracy of the report. The entity has 30 days from receiving the notice, and can apply for an extension of up to 30 more days.

What is the penalty for not filing the international group report?

Section 459 sets the penalties for reporting entities:

Default	Penalty	Source
Failure to furnish the report	Rs 5,000 a day while the failure lasts up to one month; Rs 15,000 a day for days beyond one month	s.459(1)
Failure to produce information on a s.511(7) notice in time	Rs 5,000 a day from the day after the period expires	s.459(2)
Failure continuing after a penalty order is served	Rs 50,000 a day from the date of service	s.459(3)
Inaccurate information in the report, not corrected as required	Rs 5,00,000	s.459(4)

Section 459(4) applies if the entity knew of the inaccuracy when filing and did not tell the authority, if it found the inaccuracy later and did not inform the authority and file the correct report within 15 days, or if it gave inaccurate information in reply to a section 511(7) notice. Rule 124(9) says any revision or correction of Form 59 is made by an intimation to the Director General of Income-tax (Systems).

Worked example 3: a 45-day delay

Assumption: an entity files its report 45 days late and no penalty order has been served before it files. The penalty is read as Rs 5,000 for each day in the first month and Rs 15,000 for each day beyond it, counting the first month as 30 days (an assumption for this illustration; confirm the counting with the authority's order).

Period	Days	Rate per day	Amount
First month	30	Rs 5,000	Rs 1,50,000
Beyond one month	15	Rs 15,000	Rs 2,25,000
Total	45		Rs 3,75,000

Common mistakes

• Assuming a foreign parent's filing covers India. The Indian entity still has to notify in Form 58 under section 511(1).
• Missing Form 58 because it falls before the report date. It is due two months before the report, not with it.
• Testing the revenue limit on the wrong year. Section 511(8) uses the consolidated revenue of the preceding accounting year, converted at the rate on that year's last day.
• Mixing up accounting years. For an Indian parent it is the tax year; for a foreign parent it is the parent's own financial year.
• Ignoring a correction. Learning of an inaccuracy and not correcting within 15 days attracts the Rs 5,00,000 penalty.
• Confusing Form 56 with Form 59. They have different limits, contents and due dates.

How can a CA firm keep track of these filings?

For firms that serve multinational clients, the hard part is the calendar: a notification two months before one date, a report 12 months after a different year-end, and a Form 56 due with the return. Finexo's practice management software for CAs lets you set these as client-wise tasks with reminders. It does not prepare or file the forms. For other transfer pricing topics, see our guide to transfer pricing and the arm's length price.

Where this is in the Act

• Section 511: furnishing of report in respect of an international group (sub-sections (1) to (10))
• Section 459: penalty for failure to furnish, or inaccurate, report
• Section 173(c): meaning of permanent establishment; section 159: agreements with other countries
• Section 171 and rule 123: information and documents kept by a constituent entity (Forms 56 and 57)
• Rule 124: authority, Forms 58, 59 and 60, time limits, Rs 6,400 crore threshold, exchange rate, corrections

This article is general information based on the text of the Act and Rules, not tax advice. Read the full text and the prescribed forms before filing.