Income Tax Form No. 59 is prescribed for filing the Country-by-Country Report (CbCR) of an international group under section 511 of the Income-tax Act, 2025 and Rule 124 of the Income-tax Rules, 2026. The report provides jurisdiction-wise information relating to the allocation of income, taxes and business activities of multinational enterprise groups.
The report must be furnished by the parent entity or alternate reporting entity of the international group if such entity is resident in India and the consolidated group revenue exceeds INR 6,400 crore. In certain situations, a constituent entity resident in India may also be required to file the report where the parent entity is resident in a jurisdiction that does not require such reporting, where there is no agreement for exchange of such reports with India, or where there has been a systemic failure in the exchange mechanism.
Form No. 59 must be filed within twelve months from the end of the reporting accounting year. In cases where systemic failure of the parent entity’s jurisdiction has been intimated, the form must be filed within six months from the end of the month in which the failure was notified.
The form contains several sections including details of the reporting entity, jurisdiction-wise allocation of income and taxes, a list of constituent entities in each jurisdiction and additional information relating to the international group. Supporting financial and operational information of the group and its constituent entities may be required while filing the form electronically through the income tax e-filing portal.
Guidance Note on Income Tax Form No. 59 – Country-by-Country Report (CbCR)
Purpose:
Relevant rule for Form No. 59 is Rule 124 of the Income-tax Rules, 2026. Form No. 59 is used for filing the Country-by-Country Report (CbCR) of an international group under section 511 of the Income-tax Act, 2025.
Who Should File:
Every parent entity or the alternate reporting entity, as the case may be, resident in India, shall, for every reporting accounting year, furnish the CbCR in Form No. 59, provided the total consolidated group revenue of the international group exceeds INR 6,400 crore.
Further, a constituent entity of an international group, resident in India, other than parent entity or the alternate reporting entity, shall furnish the CbCR in Form No. 59, in respect of the international group for a reporting accounting year within 12 months from the end of the reporting accounting year, if the parent entity is resident of a country or territory:
- where the parent entity is not obligated to file the report of the nature of Form No. 59 (CbCR); or
- with which India does not have an agreement providing for exchange of the report of the nature of Form No. 59 (CbCR); or
- there has been a systemic failure of the country or territory and the said failure has been intimated by the prescribed authority to such constituent entity;
However, where conditions of section 511(6) are satisfied, the CbCR under section 511(4) will not be required to be filed.
Frequency & Due Dates:
Form No. 59 is required to be filed within 12 months from the end of the reporting accounting year. In case, the parent entity of the constituent entity is resident of a country or territory, where, there has been a systemic failure of the country or territory and the said failure has been intimated to such constituent entity, the period for filing shall be within six months from the end of the month in which the said systemic failure has been intimated.
Structure of Form No. 59:
The structure and required information in Form No. 59 include:
Part A: Particulars of Reporting Entity
Part B: Other basic details
Part C: Overview of Allocation of Income, Taxes and Business Activities by Tax Jurisdiction
Part D: List of all the Constituent Entities of the Multinational Enterprise Group included in Each Aggregation Per Tax Jurisdiction (Details to be filled constituent entities wise)
Part E: Additional information
What are the documents required to file Form No. 59?
The following information/document in relation to the interanion group may be required for filing Form No. 59:
- Consolidated financial statement of the international group
- Jurisdiction-wise financial and operational information
- Constituent entity-wise financial and operational information of all constituent entities of the international group
What is the process flow of filing Form No. 59?
Form No. 59 is an e-Form, and following are the steps to file it online:
- Login to the e-filing portal
- On the dashboard, click ‘e-File’ > ‘Income Tax forms’ > ‘File Income Tax Forms’
- Scroll down to select Form No. 59
- Alternatively, enter Form No. 59 in the search box. Click on ‘File now’ button to proceed
- After checking the documents required for filing the form click on ‘Let’s Get Started’
- Fill all the necessary details and click on ‘Preview’
- After reviewing all the information, ‘Proceed’ to e-Verify’
- After verification Click on ‘Yes’ to submit the Form.
