Form 15CA / 15CB

Every outward remittance from India that is chargeable to tax in the hands of the non-resident — whether a business payment, a professional fee, a royalty, an interest payment, a dividend, an FTS payment, an import where the supplier is taxed in India, or a personal remittance crossing the threshold — passes through two checkpoints before the AD bank releases the funds. Form 15CA is the remitter's online declaration on the Income Tax e-filing portal. Form 15CB is the Chartered Accountant's certificate, also filed online, confirming the taxability position and the tax deducted at source under Section 195 of the Income Tax Act.

By FY 2026-27, the 15CA / 15CB workflow is fully digital and tightly validated. Form 10F is mandatorily e-filed for every non-resident claiming DTAA relief — paper Form 10F is no longer accepted. Tax Residency Certificate (TRC) from the beneficiary's country, beneficial-ownership declaration, and PAN of the non-resident (or the prescribed alternatives under Rule 37BC) are validated on the portal. The portal cross-checks AIS, TDS challans and PAN data — any inconsistency is rejected at filing. The bank then runs its own AD-side compliance — A2 form, FEMA purpose code, source of funds — before SWIFT release.

We handle the full lifecycle — taxability analysis under Section 195 read with the relevant DTAA, Form 10F e-filing, TRC validation, lower-deduction certificate under Section 197 where the headline rate over-deducts, TDS deposit through Form 27Q, 15CB certification by the CA, 15CA filing by the remitter, and AD-bank coordination — so the remittance leaves on time and stays audit-ready.

When 15CA / 15CB Applies — Rule 37BB Parts A, B, C, D

Part A: Single remittance up to ₹5 lakh in a financial year (aggregate test) — only Part A declaration by remitter; no CA certificate needed.

Part B: Remittance above ₹5 lakh where the remitter has obtained an order or certificate from the Assessing Officer under Section 195(2), 195(3) or 197 — Part B declaration referencing the AO order; no separate CA certificate.

Part C: Remittance above ₹5 lakh that is chargeable to tax in India and no AO order is in hand — Form 15CB by a CA + Form 15CA Part C by the remitter referencing the 15CB acknowledgement number and UDIN.

Part D: Remittance not chargeable to tax in India under the Income Tax Act — covered in the Rule 37BB specified list (33 categories such as personal gifts within LRS, certain imports, indemnity bond claims, refunds) — Part D declaration only; no CA certificate.

Types of Remittance We Certify

Cross-Border Business Payments: Royalty, fees for technical services (FTS), professional fees, software / SaaS subscriptions, equipment hire, equalisation levy interplay.
Imports & Trade Payments: Where the supplier has a business connection / PE in India and the payment is chargeable; advance against imports beyond prescribed limits.
Capital Account Remittances: Dividends, ECB interest, buyback proceeds, FDI exit consideration, ODI servicing.
NRI / Property Sale Proceeds: Capital gains TDS, indexation, Section 54 / 54EC reinvestment relief, NRO-to-overseas remittance under USD 1 million FEMA cap.
LRS & Personal Remittances: Education, medical treatment, gifts, maintenance — TCS implications post-Budget amendments.
Inter-Company Charges: Group cost allocations, management fees, secondment recoveries — transfer-pricing alignment, mark-up, beneficial-owner test.

DTAA Relief Sequence — Five Documents That Must Tie

(1) TRC from the beneficiary's home tax authority for the relevant period, in the prescribed form.
(2) Form 10F e-filed on the Income Tax portal — paper not accepted from FY 2023-24 onward.
(3) Beneficial-ownership declaration — confirming the recipient is the beneficial owner, not a conduit.
(4) PAN of the non-resident — or the prescribed alternative information under Rule 37BC.
(5) 15CB referencing the specific DTAA article (royalty, FTS, business profits, dividend, interest) and the lower of Act / treaty rate applied.

Missing any one of these collapses the DTAA claim and reverts TDS to the higher Act rate (often 20%-30% plus surcharge & cess) — and the remitter then has to either gross-up or absorb the difference.

Section 197 Lower-Deduction Certificate — When the Headline Rate Over-Deducts

For property sales, capital gains and certain trade payments, the headline Section 195 / 194-IA rate is applied on the gross sale value or invoice — not on the actual income. The seller / recipient can apply to the jurisdictional Assessing Officer under Section 197 for a lower-deduction certificate that caps TDS at the actual tax liability. Saves 5-15% of the gross amount in working capital. We handle the Section 197 application 30-45 days before the remittance.

Bank-Side Compliance — Why 15CA / 15CB Is Not the End

Even after 15CA / 15CB are filed, the AD bank runs its own compliance — A2 form, FEMA purpose code (S0001 - S1499), source of funds, KYC of remitter, beneficiary bank details, SWIFT format. We pre-align the 15CA / 15CB purpose code with the bank's A2 purpose code so there is no mismatch — the most common reason banks reject otherwise-valid 15CA / 15CB submissions.

Why Most 15CA / 15CB Filings Fail

Wrong nature-of-remittance code. Form 10F still on paper. TRC expired or in wrong format. PAN of non-resident missing without Rule 37BC compliance. DTAA rate applied without TRC. AO Section 197 / 195 order not referenced in Part B. 15CA Part C filed before 15CB acknowledgement is generated. AIS-PAN-TDS data inconsistent. We pre-validate every input before filing.