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Direct Tax Code / Income Tax

Country-by-Country Reporting (CbCR) — Who Must File and When

A comprehensive guide to country-by-country reporting under the Income Tax Act, 2025, explaining who must file, when to file, and the applicable thresholds.

25 Jul 20263 min read

Country-by-Country Reporting is a cornerstone of the OECD's Base Erosion and Profit Shifting framework, providing tax authorities with a comprehensive view of multinational enterprise operations. The Income Tax Act, 2025, through Section 511 and Rule 124, establishes India's CbCR framework . Understanding who must file and when is essential for multinational enterprises.

The Statutory Framework

Section 511

Section 511 requires constituent entities resident in India to notify the prescribed authority about their status in the international group and to furnish reports on behalf of the group .

Rule 124

Rule 124 designates the Joint Director notified by the Director General of Income-tax (Systems) as the income-tax authority for CbCR purposes .

Who Must File

Parent Entity or Alternate Reporting Entity

Every parent entity or alternate reporting entity resident in India must file a CbCR in Form No. 59 for every reporting accounting year, provided the total consolidated group revenue of the international group exceeds ₹6,400 crore .

Constituent Entity

A constituent entity resident in India, other than the parent entity or alternate reporting entity, must file the CbCR if the parent entity is resident in a jurisdiction where :

  • The parent entity is not obligated to file the report
  • India does not have an agreement for exchange of such reports
  • There has been a systemic failure in the exchange mechanism

Exceptions

Where conditions of Section 511(6) are satisfied, the CbCR under Section 511(4) will not be required to be filed .

Filing Deadlines

General Deadline

Form No. 59 must be filed within twelve months from the end of the reporting accounting year .

Systemic Failure Cases

In cases where the parent entity's jurisdiction has experienced systemic failure, the form must be filed within six months from the end of the month in which the failure was notified .

Notification Requirement

The notification under Section 511(1) must be made in Form No. 58 at least two months prior to the due date for furnishing the report .

Thresholds

CbCR Threshold

The CbCR filing obligation applies where the total consolidated group revenue of the international group equals or exceeds ₹6,400 crore .

Foreign Currency Conversion

Where the total consolidated group revenue is in foreign currency, the rate of exchange for conversion shall be the telegraphic transfer buying rate of such currency on the last day of the accounting year preceding the accounting year .

Content of CbCR

Form No. 59 provides jurisdiction-wise information relating to :

  • Allocation of income
  • Allocation of taxes
  • Business activities of multinational enterprise groups

Expert Legal Guidance

Understanding CbCR requirements is essential for multinational enterprises. Anuj Desai & Associates provides expert advisory services on international tax compliance, helping taxpayers navigate CbCR filing obligations.


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