Form 59 Income Tax Rules 2026 pdf download and Key points
FORM NO. 59
[See rule 124(3)]
COUNTRY-BY-COUNTRY REPORT
Report by a parent entity or an alternate reporting entity or any other constituent entity, resident in India, for the purposes of section 511(2) or section 511(4)
Under the Income-tax Rules, 2026, Form No. 59 is the statutory Country-by-Country Report (CbCR). It is governed by Section 511 of the Income-tax Act, 2025, and Rule 124 of the Income-tax Rules, 2026.
Here are all the key points regarding Form No. 59:
1. Purpose of the Form Form 59 is used for filing the Country-by-Country Report (CbCR) of an international group or Multinational Enterprise (MNE). It provides tax authorities with a global picture of the group’s revenue, income, taxes, and business activities broken down by tax jurisdiction.
2. Applicability (Who Should File) The form must be filed by the following entities resident in India:
- Parent or Alternate Reporting Entity: Every parent entity or alternate reporting entity resident in India must file Form 59, provided the total consolidated group revenue of the international group exceeds ₹6,400 crore.
- Constituent Entity (Under Special Circumstances): A constituent entity resident in India (other than the parent or alternate reporting entity) must furnish Form 59 if the parent entity is resident in a country or territory:
- Where the parent entity is not legally obligated to file a CbCR.
- With which India does not have an agreement for the exchange of CbCRs.
- Where there has been a systemic failure to exchange information, and this failure has been officially intimated to the constituent entity. (Note: If the conditions of section 511(6) are satisfied, this secondary filing requirement may be waived.)
3. Frequency and Due Dates
- Standard Due Date: Form 59 must be filed within 12 months from the end of the reporting accounting year.
- In Case of Systemic Failure: If the constituent entity is filing because of an intimated systemic failure in the parent entity’s country, the deadline is within six months from the end of the month in which the systemic failure was intimated.
4. Structure of the Form Form 59 is comprehensively structured to capture jurisdictional and entity-wise data:
- Part A: Particulars of the Reporting Entity.
- Part B: Other basic details.
- Part C: Overview of Allocation of Income, Taxes, and Business Activities mapped out by Tax Jurisdiction.
- Part D: List of all the Constituent Entities of the MNE Group included in Each Aggregation Per Tax Jurisdiction (these details must be filled constituent entity-wise).
- Part E: Additional information.
5. Mandatory Documents and Information Required To successfully file Form 59, the reporting entity must have the following information and documents ready:
- The consolidated financial statement of the international group.
- Jurisdiction-wise financial and operational information.
- Constituent entity-wise financial and operational information covering all constituent entities of the group.
6. Mode of Filing and Verification
- Online Only: Form 59 is an e-Form and must be filed online through the Income Tax e-Filing portal (under ‘e-File’ > ‘Income Tax forms’ > ‘File Income Tax Forms’).
- Process: The taxpayer must fill out all the necessary details, preview the information, and then officially e-Verify the form before clicking ‘Yes’ to submit it.
