Section 511 · Miscellaneous
Section 511 of the Income-tax Act, 2025 — Country-by-Country Report (CbCR) for International Groups
By CA Rajat Agrawal
Updated 05 Jul 2026
Chapter XXIII
📜 What the law says — Section 511, Income-tax Act 2025
511. (1) Every constituent entity resident in India, shall, if it is constituent of an
international group, the parent entity of which is not resident in India, notify
the prescribed income-tax authority in the form and manner, on or before such
date, as may be prescribed,—
(a) whether it is the alternate reporting entity of the international group; or
(b) the details of the parent entity or the alternate reporting entity, if any, of
the international group, and the country or territory of which the said
entities are resident.
(2) Every parent entity or the alternate reporting entity, resident in India, shall,
for every reporting accounting year, in respect of the international group of which
it is a constituent, furnish a report, to the prescribed income-tax authority within
twelve months from the end of the said reporting accounting year, in such form and
manner, as may be prescribed.
(3) In sub-sections (2) and (4), the report in respect of an international group shall
include—
(a) the aggregate information in respect of the amount of revenue, profit or
loss before income-tax, amount of income-tax paid, amount of income-tax
accrued, stated capital, accumulated earnings, number of employees and
tangible assets not being cash or cash equivalents, with regard to each
country or territory in which the group operates;
(b) the details of each constituent entity of the group including the country
or territory in which such constituent entity is incorporated or organised
or established and the country or territory where it is resident;
(c) the nature and details of the main business activity or activities of each
constituent entity; and
(d) any other information, as may be prescribed.
(4) A constituent entity of an international group, resident in India, other than the
entity referred to in sub-section (2), shall furnish the report referred to in the said
sub-section, in respect of the international group for a reporting accounting year
within the period, as may be prescribed, if the parent entity is resident of a country
or territory,—
(a) where the parent entity is not obligated to file the report of the nature
referred to in the said sub-section; or
(b) with which India does not have an agreement providing for exchange of
the report of the nature referred to in the said sub-sect
In plain language
What Section 511 is about
Section 511 of the Income-tax Act, 2025 contains India's Country-by-Country Reporting (CbCR) rules for large multinational (MNE) groups. It is the re-numbered successor to Section 286 of the Income-tax Act, 1961 — the subject matter, thresholds and mechanics are carried forward almost unchanged. The idea comes from the OECD/G20 BEPS Action 13 project: very large international groups must file a single global report showing, country by country, how much revenue, profit, tax and economic substance (employees, assets, capital) they have in each territory. Tax authorities use it to spot profit-shifting to low-tax jurisdictions.
Who it applies to
- Large international groups only. The rules bite only where the group's total consolidated group revenue in the immediately preceding accounting year exceeds the prescribed threshold — ₹6,400 crore (aligned to the OECD's EUR 750 million benchmark). Below this, Section 511 does not apply.
- Parent entity resident in India — the ultimate holding company that prepares consolidated accounts must file the CbC report with the prescribed income-tax authority.
- Alternate Reporting Entity (ARE) resident in India — a group entity nominated by a foreign parent to file on the group's behalf.
- Any Indian constituent entity whose parent is a non-resident — it must at minimum notify the department of the reporting entity's identity and residence, and in "backup" situations must itself file the full report.
Key obligations and deadlines
- Notification: An Indian constituent entity of a group headed by a foreign parent must tell the department who the reporting entity is and its country of residence, in the prescribed form (Form 3CEAC), within the prescribed time (customarily two months before the CbCR due date).
- CbC report filing: The Indian parent/ARE must furnish the report within 12 months from the end of the reporting accounting year, in Form 3CEAD.
- Master File: Related documentation (Form 3CEAA, with intimation in Form 3CEAB where multiple Indian entities exist) supports the group-level picture, though that flows from the transfer-pricing documentation rules.
What the report must contain (sub-section 3)
- For each country/territory: aggregate revenue, profit or loss before income-tax, income-tax paid, income-tax accrued, stated capital, accumulated earnings, number of employees, and tangible assets (other than cash).
- For each constituent entity: its country of incorporation/residence and its main business activities.
Backup and secondary filing (sub-sections 4–6)
An Indian constituent entity of a foreign-parented group must file the full CbC report in India itself if: the parent's country does not require CbCR; India has no exchange agreement with that country; or there is a "systemic failure" in exchange. Where several Indian entities are caught, the group may designate one entity to file for all (sub-section 5). No Indian filing is needed if an ARE has already filed in an eligible jurisdiction that exchanges with India (sub-section 6).
How it interacts with other provisions
- Master File / transfer pricing documentation — CbCR sits alongside the three-tiered TP documentation (Master File, Local File, CbC report).
- Permanent establishment — "PE" for these rules is read with the definition in Section 173(c) of the 2025 Act.
- Penalties — failure to furnish, or furnishing inaccurate information, attracts heavy penalties (the 2025 Act carries forward the old Section 271GB scheme; a "reasonable cause" defence akin to Section 273B applies).
Practical implications
For the vast majority of Indian taxpayers and even most domestic companies, Section 511 is irrelevant — it only touches groups above the ₹6,400 crore consolidated-revenue mark. But for genuinely large MNEs, missing the notification (Form 3CEAC) or the 12-month CbCR (Form 3CEAD) deadline is costly, with daily penalties. Group CFOs should map their reporting entity early, confirm exchange relationships, and diarise both the notification and filing dates.
💡 Example
Worked example 1 — Indian-headquartered group. Bharat Global Ltd is the ultimate parent of a group with a consolidated turnover of ₹9,200 crore for the year ended 31 March 2026. Because ₹9,200 crore exceeds the ₹6,400 crore threshold, Section 511 applies for accounting year 2026-27. Bharat Global must file the CbC report in Form 3CEAD by 31 March 2028 (12 months from the 31 March 2027 year-end of the reporting accounting year), disclosing per-country revenue, profits, taxes and headcount for all its subsidiaries in the UK, Singapore and UAE.
Worked example 2 — Indian subsidiary of a foreign parent. TechCo India Pvt Ltd is a constituent entity of a US-headquartered group with consolidated revenue of ₹15,000 crore. TechCo India does not file the CbC report itself (the US parent does), but it must notify the Indian tax authority in Form 3CEAC of the US parent's name and residence before the due date. If TechCo India misses this notification, penalties can run at ₹5,000 per day (rising to ₹15,000 per day beyond one month, under the carried-forward 271GB-style scheme).
Relatable story. Think of the CbC report like a family that owns shops in ten cities filing one combined statement showing how much each shop earned and how much tax it paid locally — so the tax office can see if the family is quietly booking all its profit in the city with the lowest tax. Small family shops (below ₹6,400 crore) never have to do this; only the biggest business families do.
| Item | Requirement under Section 511 (2025 Act) |
|---|
| Old-law equivalent | Section 286 of the Income-tax Act, 1961 |
| Revenue threshold | Consolidated group revenue > ₹6,400 crore in the preceding accounting year (≈ EUR 750 million) |
| Notification form (Indian constituent of foreign parent) | Form 3CEAC |
| CbC report form | Form 3CEAD |
| Master File forms | Form 3CEAA (with Form 3CEAB intimation where multiple Indian entities) |
| CbCR filing deadline | Within 12 months from the end of the reporting accounting year |
| Document production on notice | Within 30 days (extendable by up to a further 30 days) |
| Penalty – failure to furnish (indicative, carried-forward scheme) | ₹5,000/day up to 1 month; ₹15,000/day beyond 1 month |
| Penalty – inaccurate information | Up to ₹5,00,000 (subject to conditions) |
Related sections
Section 286 (Act 1961) — Original CbCR provision (predecessor) Section 173 — Definitions including permanent establishment (clause c) Section 271GB (Act 1961) — Penalty for CbCR default (carried forward) Section 273B (Act 1961) — No penalty for reasonable cause Section 92D (Act 1961) — Transfer pricing / Master File documentation Section 510 — Related international-group / transfer-pricing reporting
Forms under this section
Income-tax forms (2025) prescribed under Section 511:
Frequently asked questions
Who has to file the Country-by-Country report under Section 511?
An Indian-resident parent entity or an alternate reporting entity of an international group whose consolidated group revenue in the preceding year exceeds ₹6,400 crore. Indian constituent entities of a foreign parent usually only notify, unless a backup-filing situation applies.
What is the revenue threshold for CbCR to apply?
Section 511 applies only if the total consolidated group revenue for the accounting year preceding the reporting year exceeds the prescribed amount, which is ₹6,400 crore (aligned to the OECD's EUR 750 million benchmark). Groups below this are exempt.
What is the deadline to file the CbC report?
The parent or alternate reporting entity resident in India must furnish the report within 12 months from the end of the reporting accounting year, in Form 3CEAD.
Which forms are used for CbCR compliance?
Form 3CEAC is the notification by an Indian constituent entity of a foreign parent, and Form 3CEAD is the Country-by-Country report itself. The related Master File uses Form 3CEAA (with Form 3CEAB intimation).
Is Section 511 the same as Section 286 of the old Act?
Yes. Section 511 of the Income-tax Act, 2025 is the renumbered successor to Section 286 of the Income-tax Act, 1961, with substantially the same thresholds, deadlines and reporting content.
What is the penalty for not filing or filing inaccurate CbCR?
Under the carried-forward scheme, failure to furnish attracts roughly ₹5,000 per day (up to one month) and ₹15,000 per day beyond one month, while furnishing inaccurate information can attract a penalty of up to ₹5,00,000, subject to conditions. A reasonable-cause defence is available.
Does a small Indian company need to worry about Section 511?
No. Unless it is part of an international group with consolidated revenue above ₹6,400 crore, Section 511 does not apply to it at all.
C
CA Rajat Agrawal
Chartered Accountant, EaseValue · Reviewed 05 Jul 2026
This explainer is prepared and reviewed by EaseValue's tax team, based on the text of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
Disclaimer: This page explains the law in general terms for education and is not professional advice. The Income-tax Act, 2025 takes effect from 1 April 2026; provisions, thresholds and interpretations may change. Please confirm your specific position with our team before acting.
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