Section 511 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Section 511 of the Income-tax Act, 2025 requires multinational groups with entities resident in India to report country-wise information about the group. It names who must notify the tax authority, who must furnish the report, when, what it must contain, and when another Indian entity must step in. Groups that need to place this reporting within wider planning can use tax planning advisory.
This explanation is as per the Income-tax Act, 2025 (30 of 2025) as amended by the Finance Act, 2026. Under section 1(3) the Act came into force on the 1st April, 2026, save as otherwise provided. Later amendments, rules and notifications should be checked.
A parent entity or alternate reporting entity resident in India must furnish the report for every reporting accounting year within twelve months from its end. A constituent entity resident in India whose parent is not resident in India must notify the prescribed authority about the group's reporting entity. Another Indian constituent entity must furnish the report only if the parent's country does not require it, has no exchange agreement with India, or has failed systemically. The section does not apply if the group's consolidated revenue for the preceding accounting year does not exceed the prescribed amount.
Sub-section (1): notification by a constituent entity
Every constituent entity resident in India that belongs to an international group whose parent entity is not resident in India shall notify the prescribed income-tax authority, in the form and manner and on or before the date 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, and the country or territory of which they are resident.
Sub-section (2): the report
Every parent entity or 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 reporting accounting year, in the prescribed form and manner.
Sub-section (3): contents of the report
The report shall include:
- (a) aggregate information on revenue, profit or loss before income-tax, income-tax paid, income-tax accrued, stated capital, accumulated earnings, number of employees and tangible assets (not cash or cash equivalents), for each country or territory in which the group operates;
- (b) details of each constituent entity, including the country or territory where it is incorporated, organised or established, and where it is resident;
- (c) the nature and details of the main business activity of each constituent entity; and
- (d) any other information as may be prescribed.
Sub-sections (4) and (5): when another Indian entity must furnish the report
A constituent entity resident in India, other than the entity in sub-section (2), shall furnish the report within the prescribed period if the parent entity is resident of a country or territory:
- (a) where the parent entity is not obligated to file such a report;
- (b) with which India does not have an agreement providing for exchange of such a report; or
- (c) where there has been a systemic failure of the country or territory, intimated by the prescribed authority to the constituent entity.
If there is more than one such constituent entity resident in India, the report may be furnished by any one of them if the group has designated that entity to furnish it on behalf of all the Indian constituent entities, and the information has been conveyed in writing on behalf of the group to the prescribed authority.
Sub-section (6): when sub-sections (4) and (5) do not apply
They do not apply if an alternate reporting entity of the group has furnished the report with the tax authority of its own country or territory on or before the date specified there, and all of these are satisfied:
- the report is required under a law in force in that country or territory;
- that country or territory has an agreement with India for exchange of the report;
- the prescribed authority has not conveyed any systemic failure in respect of that country or territory to any Indian constituent entity of the group;
- that country or territory has been informed in writing by the constituent entity that it is the alternate reporting entity on behalf of the group; and
- the prescribed authority has been informed by the entity referred to in sub-sections (4) and (5), as per sub-section (1).
Sub-sections (7) to (9): notice, threshold and conditions
- Notice (7). To determine the accuracy of the report, the prescribed authority may issue a written notice requiring the entity to produce the information and documents specified, within thirty days of receipt. The period may be extended by up to an additional thirty days on application by the entity.
- Threshold (8). The section does not apply to an international group for an accounting year if the total consolidated group revenue, per the consolidated financial statement for the preceding accounting year, does not exceed the prescribed amount. The Act prints no figure; it is left to the rules and is not in the text consulted.
- Guidelines (9). The section is applied as per such guidelines and subject to such conditions as may be prescribed.
| Time limit in section 511 | Period |
|---|---|
| Report by parent or alternate reporting entity resident in India | Within twelve months from the end of the reporting accounting year |
| Producing information after a notice (sub-section (7)) | Thirty days from receipt; extendable by up to an additional thirty days on application |
| Notification under sub-section (1) | On or before the date prescribed |
| Report by another Indian entity under sub-section (4) | Within the period prescribed |
Sub-section (10): the definitions
| Term | Meaning in section 511(10) |
|---|---|
| Accounting year | A tax year where the parent entity is resident in India; otherwise the annual accounting period for which the parent prepares its financial statements under any law in force or the applicable accounting standards of its country or territory |
| Agreement | A combination of an agreement entered into under section 159(1) or (2) and an agreement for exchange of the report notified by the Central Government |
| Alternate reporting entity | A constituent entity designated by the group, in place of the parent entity, to furnish the report in the country or territory in which it is resident |
| Constituent entity | A separate entity of an international group included, or which may be included if the group's equity share were listed, in the consolidated financial statement; an entity excluded solely on size or materiality; or a permanent establishment of such an entity which prepares a separate financial statement for the stated purposes |
| Group | A parent entity and all entities for which a consolidated financial statement is, or would be if listed, required |
| Consolidated financial statement | A statement presenting assets, liabilities, income, expenses and cash flows of the parent and constituent entities as those of a single economic entity |
| International group | A group including two or more enterprises resident in different countries or territories, or an enterprise resident in one country carrying on business through a permanent establishment in another |
| Parent entity | A constituent entity holding, directly or indirectly, an interest in one or more others, which must prepare (or would if listed) a consolidated financial statement, and which is not itself included in another constituent entity's consolidated statement |
| Permanent establishment | As assigned in section 173(c) |
| Reporting accounting year | The accounting year for which the results are to be reflected in the report |
| Reporting entity | The constituent entity, including the parent or alternate reporting entity, required to furnish the report |
| Systemic failure | The country or territory has an exchange agreement with India but has suspended automatic exchange in violation of it, or has persistently failed to automatically provide India the report in its possession for any group with an Indian constituent entity |
The definitions are lengthy; read the official text of section 511(10) for the exact wording.
A worked example (names and facts assumed)
Orchid Global Holdings is the parent entity of an international group. Its constituent entities include Orchid India Private Limited, resident in India. The parent entity is resident in a country that has no agreement with India for exchange of the report. (All names and facts are assumed.)
- Under sub-section (1), Orchid India notifies the prescribed authority about the parent entity, its country, and whether Orchid India itself is the alternate reporting entity.
- Because the parent's country has no exchange agreement with India, sub-section (4)(b) applies, and Orchid India must furnish the report within the prescribed period.
- If the group has another Indian entity, Orchid Services Private Limited, the group may designate one of them to furnish the report on behalf of both under sub-section (5), conveying this in writing to the authority.
- If the group's consolidated revenue for the preceding accounting year does not exceed the prescribed amount, the whole section does not apply (sub-section (8)).
If a group's alternate reporting entity files in a country with an exchange agreement and all five conditions in sub-section (6) are met, the Indian entity need not file under sub-sections (4) and (5).
Need help with group reporting?
Multinational groups with Indian entities should work out early who the reporting entity is, what the prescribed threshold and periods are, and who in India files. Our tax planning advisory team can help you map the group structure against these provisions.
Key takeaways
- A constituent entity in India whose parent is not resident in India must notify the authority (section 511(1)).
- A parent or alternate reporting entity resident in India furnishes the report within twelve months of the reporting accounting year end (section 511(2)).
- The report carries country-wise aggregates, entity details and business activities (section 511(3)).
- Another Indian entity files if the parent's country does not require the report, has no exchange agreement, or has a systemic failure (section 511(4)).
- The authority can issue a notice with thirty days to respond, extendable by up to thirty more (section 511(7)).
- Groups below the prescribed consolidated revenue are outside the section (section 511(8)).
Read next
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- Section 159: relief under an agreement with another country
- Section 161: transfer pricing
Disclaimer: Based on the Income-tax Act, 2025 (30 of 2025) as amended by the Finance Act, 2026, as consulted on 2 October 2026. It explains the words of the Act only; the Income-tax Rules, 2026, notifications, circulars, later amendments and the way the tax authorities and courts apply these provisions should be checked. This article is general information, not legal advice; check the official text before acting.