Rule 124: Country-by-country reporting and Forms 58–60
Rule 124 supplies the authority, forms and procedural details for section 511 international-group reporting. Read it with the parent section to establish which entity must report, then apply the relevant form, deadline and revenue conversion rule.
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Rule 124 - Furnishing of report in respect of an international group under section 511
(1) The income-tax authority for the purposes of section 511 shall be the Joint Director, as may be designated by the Director General of Income-tax (Systems).
(2) The notification under section 511(1) shall be made in Form No. 58 two months prior to the due date for furnishing of report as specified under sub-section (2) of the said section.
(3) Every parent entity or the alternate reporting entity, as the case may be, resident in India, shall, for every reporting accounting year, furnish the report referred to in section 511(2) in Form No. 59.
(4) The period for furnishing of the report under section 511(4) by the constituent entity, referred to in that sub-section shall be twelve months from the end of the reporting accounting year.
(5) 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 submission of the report shall be six months from the end of the month in which said systemic failure has been intimated.
(6) The information required to be conveyed under section 511(5) regarding the designated constituent entity shall be furnished in Form No. 60.
(7) For the purposes of section 511(8), the total consolidated group revenue of the international group shall be six thousand four hundred crore rupees.
(8) Where the total consolidated group revenue of the international group, as reflected in the consolidated financial statement, is in foreign currency, the rate of exchange for the calculation of the value in rupees of such total consolidated group revenue shall be the telegraphic transfer buying rate of such currency on the last day of the accounting year preceding the accounting year.
(9) Any revision or correction in the report furnished in the Form No. 59 shall be made by furnishing an intimation to the Director General of Income-tax (Systems).
(10) For the purposes of this rule, — (a) the expressions ―accounting year‖, ―consolidated financial statement‖ and ―international group‖ shall have the meanings respectively assigned to them in section 511(10); and (b) ―telegraphic transfer buying rate‖ shall have the meaning assigned in rule 207.
Rule breakdown
Identify the reporting entity and authority
The authority is the Joint Director designated by the Director General of Income-tax (Systems). An Indian-resident parent or alternate reporting entity furnishes the section 511(2) report in Form 59 for each reporting accounting year.
Determine the entity’s statutory role first; the existence of an Indian group member does not by itself answer every parent-section reporting condition.
Forms 58 and 60 serve different purposes
The section 511(1) notification is Form 58, due two months before the report due date specified in section 511(2). Form 60 conveys the section 511(5) information about the designated constituent entity.
Keep notification, designation and the actual Form 59 report as separate compliance items.
Constituent-entity and systemic-failure deadlines
The section 511(4) constituent-entity reporting period is twelve months from the end of the reporting accounting year. Where the specified systemic failure in the parent’s jurisdiction is intimated, the rule provides six months from the end of the intimation month.
Record the accounting-year end and any formal failure intimation. Do not substitute a general twelve-month clock without checking the applicable branch.
Revenue threshold and foreign-currency conversion
The prescribed consolidated group revenue for section 511(8) is ₹6,400 crore. Apply the parent section’s threshold operation and relevant period, rather than treating the number alone as the full test.
For foreign-currency revenue, use the telegraphic-transfer buying rate on the last day of the accounting year preceding the accounting year, as stated in sub-rule (8). This differs from Rule 123’s date.
Corrections require an intimation
A revision or correction to Form 59 is made by furnishing an intimation to the Director General of Income-tax (Systems). Retain the original report, correction details and supporting reconciliation.
Confirm the current official submission procedure rather than assuming an undocumented replacement file is sufficient.
Key takeaways
Three distinct forms
Notification, report and designated-entity information are separate.
Branch-specific timing
Check constituent-entity and systemic-failure cases.
₹6,400 crore prescribed amount
Read it with section 511(8).
Preceding-year conversion date
Use the exact exchange-date provision.
Practical checklist
- Confirm the entity’s role under section 511.
- Calendar notification and reporting separately.
- Retain currency-conversion and any systemic-failure evidence.
Avoid
- Do not confuse Forms 58,59 and 60.
- Do not use Rule 123’s exchange date for this rule.
FAQs
Which form contains the parent or alternate entity report?
Form 59 under sub-rule (3).
When is Form 58 due?
Two months before the report due date referred to in section 511(2).
How is a Form 59 correction made under this rule?
By furnishing an intimation to the Director General of Income-tax (Systems).
Glossary
- Form 59
- The report form prescribed for the section 511 reporting framework.