Rule 123 requires a constituent entity of an international group above set revenue and transaction values to keep and furnish group-level information in Form No. 56, lists the information, and sets the due date, designation of one filer, nine-year retention and exchange rate.
123
Rules 2026 · Rule 123
Maintenance and furnishing of information and document by constituent entity of an international group under section 171
Rules 77-130
Who must keep it (sub-rule 1). A constituent entity of an international group where (a) the consolidated group revenue in the consolidated financial statement for the accounting year exceeds five hundred crore rupees; and (b) the aggregate value of international transactions exceeds fifty crore rupees in the accounting year, or, for purchase, sale, transfer, lease or use of intangible property, exceeds ten crore rupees.
What to keep. A list of group entities with addresses; a chart of the entity's legal status and the group's ownership; a description of the group's business (nature, profit drivers, supply chains for the five largest products or services and any above 5% of consolidated revenue, important intra-group service arrangements, the main service providers' capabilities, service-cost transfer pricing policies, major geographical markets, functions, assets and risks of entities contributing at least 10% of revenues, assets or profits, and important restructuring, acquisitions and divestments); the intangible property strategy, the entities that develop and manage it, the important intangibles and their legal owners, important agreements on them, transfer pricing policies on research and development and intangibles, and important transfers of interest; the financing arrangements (including the top ten unrelated lenders), central financing entities and financing transfer pricing policies; the annual consolidated financial statement; and existing unilateral advance pricing agreements and other tax rulings.
Furnishing (sub-rules 2 to 4). To the Joint Director referred to in rule 124(1), in Form No. 56, on or before the return due date under section 263(1)(c). Part A of Form No. 56 is furnished even if the sub-rule (1) conditions are not met. Where several constituent entities are required to file, any one may do so if the group has designated it and told the Joint Director in Form No. 57 thirty days before the Form No. 56 due date.
Retention and conversion (sub-rules 5 to 7). The information is kept for nine years from the end of the relevant tax year. Consolidated group revenue in foreign currency is converted at the telegraphic transfer buying rate on the last day of the accounting year (defined in rule 207). "Accounting year", "consolidated financial statement" and "international group" have the meanings in section 511(10).