Form 50 under Section 168 of the Income-tax Act, 2025 is an optional application used by taxpayers seeking a pre-filing consultation for entering into an Advance Pricing Agreement (APA) with tax authorities. It enables taxpayers to discuss and present their proposed transfer pricing methodology for international transactions before filing a formal APA application. There is no prescribed time limit for filing, but it must be submitted before undertaking the relevant transaction, and it can be filed once annually through the e-filing portal. The form allows anonymous filing, requiring only authorised representative details in such cases, and cannot be edited once submitted. It requires no specific supporting documents but includes details such as transaction scope, business profile, and proposed APA terms through annexures. The process involves review and consultation by designated APA teams. Overall, Form 50 facilitates early engagement, reduces disputes, and improves certainty in transfer pricing matters.
Income Tax Department
Ministry of Finance, Government of India
FAQs on Income Tax Form 50: Application for a pre-filing consultation under Income Tax Act, 2025
Form of application under section 168 of the Income-tax Act, 2025
| Name of form as per I.T. Rules, 1962 | Form 50 | Name of form as per I.T. Rules, 2026 | 50 |
| Corresponding section of I.T. Act, 1961 | 92CC | Corresponding section of I.T. Act, 2025 | 168 |
| Corresponding Rule of I.T. Rules, 1962 | 10H | Corresponding Rule of I.T. Rules, 2026 | 105 |
Q1: What is Form 50 ?
Ans: Form 50 is an income tax form used to apply for a pre-filing meeting with regards to an Advance Pricing Agreement (APA). An APA is an agreement between a taxpayer and the tax authority to determine the transfer pricing methodology for transactions between associated enterprises in advance.
Q2: Who should file Form 50?
Ans: Any taxpayer who wishes to enter into an Advance Pricing Agreement with the Indian tax authorities should file Form 50 to request a pre-filing meeting. This meeting is an opportunity for the taxpayer to present their proposed transfer pricing methodology and discuss it with the tax authorities before formally applying for the APA.
Q3: Is Form 50 mandatory?
Ans: Form 50 is optional. It is filed only if the taxpayer intends to apply for an Advanced Pricing Agreement.
Q4: What is the time limit for filing Form 50?
Ans: There is no time limit for filing Form 50. It can be filed as and when required to be filed by Applicant, before undertaking the international transaction.
Q5: How many times can Form 50 be filed in a year?
Ans: Form 50 can be filed once in a year.
Q6: What documents are required to file Form 50?
Ans: No specific documents are required for filing Form 50.
Q7: Can I edit Form 50 after submission?
Ans: No. Once Form 50 is submitted and acknowledgment is generated, it cannot be edited. Ensure all details are correct before submission.
Q8: Can I file Form 50 anonymously?
Ans: Yes, Form 50 can be filed anonymously. In case the pre-filing meeting is requested on an anonymous basis, no names of the applicant or associated enterprises are to be given. In such cases, details of the authorised representatives of the applicant namely: name, address and contact details (phone number and e-mail id) will be mandatory.
Q9: Can Form 50 be filed offline?
Ans: No. Form 50 can only be submitted online through the Income Tax e-Filing portal.
Q10: Why is Form 50 important?
Ans: Any taxpayer who wishes to enter into an Advance Pricing Agreement with the Indian tax authorities should file Form 50 to request a pre-filing meeting. This meeting is an opportunity for the taxpayer to present their proposed transfer pricing methodology and discuss it with the tax authorities before formally applying for the APA.
Guidance Note on Income Tax Form 50: Application for a pre-filing consultation under Income Tax Act, 2025
| Name of form as per I.T. Rules, 1962 | Form 3CEC | Name of form as per I.T. Rules, 2026 | 50 |
| Corresponding section of I.T. Act, 1961 | 92CC | Corresponding section of I.T. Act, 2025 | 168 |
| Corresponding Rule of I.T. Rules, 1962 | 10H | Corresponding Rule of I.T. Rules, 2026 | 105 |
Form FN050- Application for pre-filing consultation
Purpose:
Form FN050 is an income tax form used to apply for a pre-filing meeting with regards to an Advance Pricing Agreement (APA). An APA is an agreement between a taxpayer and the tax authority to determine the transfer pricing methodology for transactions between associated enterprises in advance. Form FN050 is filed under Rule 105 of the Income-tax Rules, 2026, and can be filed by person to eligible to apply under Rule 104 of the Income-tax Rules, 2026.
Who Should File:
Any taxpayer who wishes to enter into an Advance Pricing Agreement with the Indian tax authorities should file Form 50 to request a pre-filing meeting. This meeting is an opportunity for the taxpayer to present their proposed transfer pricing methodology and discuss it with the tax authorities before formally applying for the APA.
Frequency & Due Dates:
As and when required to be filed by Applicant, before undertaking the international transaction.
Structure of Form 50:
> Part A: Particulars of the Person
> Part B: Other Details:
-
- Type of APA proposed (Unilateral/Bilateral/Multilateral)
- Detail of International transactions proposed to be covered in the Advance Pricing Agreement (APA)
- Tax years for which APA is proposed to be applied including the rollback years
> Other Details to be provided as Annexures:
| Annexure | Particulars | ||||||
| A-1 | The global structure of the applicant’s group and the industry in which it operates. | ||||||
| A-2 | Business model and overview of the applicant’s business operations in prior 3 tax years. | ||||||
| A-3 | Functional Profile of the applicant and associated enterprises. | ||||||
| A-4 | History of transfer pricing audits and present status of appeals. | ||||||
| Ta | Disputed International Transact ion | Amount of Adjustment | Decision of each appellate authority | Current status | |||
| A-5 | The details of all other international transaction not proposed to be covered in the APA. | ||||||
What are the documents required to file the Form 50?
No specific documents required
Filing Count:
On average, about 16 Forms are filed annually over the last two years.
What is the process flow of filing Form FN050?
The process flow includes following steps:
1. The Applicant shall file Form 50 electronically to the Principal Chief Commissioner of Income- tax (International Taxation) or the Competent Authority in India (in case of Bilateral/Multilateral transactions).
2. The PCCIT (IT)/Competent Authority shall assign the application to one of the 5 APA teams.
3. On receipt of the Application, the APA team shall hold pre-filing consultation with the Applicant. For consultations involving bilateral or multilateral agreement, the competent authority in India or their representative shall also be associated.
Outcome of Processed Form FN050:
- On receipt of the Form 50, The PCCIT (IT) shall assign the application to one of the APA teams.
- The APA team receiving the assignation shall hold pre-filing consultation with the Applicant.
- For consultations involving bilateral or multilateral agreement, the competent authority in India or their representative shall also be associated. The discussion shall be along the lines as mentioned in Rule RN105 of the Income-tax Rules, 2026.
Brief note on broad or qualitative changes proposed:
- No major changes have been incorporated into the Form
- For added simplicity, certain details asked for in the main Form earlier have been proposed to be taken as annexures in a separate enclosure
- Extraneous information previously asked for in the Form which would not be applicable at Pre-filing stage has been omitted for enhanced clarity
- To facilitate anonymous filings of applications for pre-filing consultations, a drop- down menu for naming an authorised representative has been introduced.
- Requirement for filing form in triplicate has been omitted
Challenges and Solutions:
In cases where the applicant prefers not to mention their names, since this is a pre-filing discussion, the filing of Form 50 earlier could be complicated. By explicitly including a data point of authorised representative, such instances shall be eliminated.
Common Changes made across Forms:
1. To make Forms system-friendly and enable e-filing and uploading, certain anomalies found due to grouping of Name, Designation, Address, PAN have been separated into different boxes.
2. Assessment / Financial / Previous year or years have been replaced with Tax year or years, wherever appearing in the Form/Annexure.
3. Sections, Clauses and Schedules changes as per the Income-tax Act, 2025.
4. Currency symbol “Rs.” has been replaced with “₹”.
