Form 15CA and 15CB for foreign remittances in 2026: when each is required, the four parts of 15CA, and the CA certificate that costs ₹15,000-50,000

The Form 15CA and Form 15CB regime governs every outward remittance from India that is chargeable to Indian tax. The framework, set out in Rule 37BB of the Income-tax Rules 1962, requires the remitter to either self-declare (Form 15CA) or obtain a CA's certificate (Form 15CB) before the bank can process the SWIFT transfer.

For corporate India in 2026, the typical use cases are: payment of foreign professional fees, royalty to a foreign group company, technical service fees to an overseas consultant, software licence fees to a foreign vendor, dividend to a foreign parent, and any other revenue or income payment that crosses the border.

This post covers the four parts of Form 15CA and when each is used, the ₹5 lakh threshold for triggering Form 15CB, the 33-item exempt list, the chartered accountant's professional responsibility, the bank's role in the chain, and the practical workflow.

The ₹5 lakh threshold

The single most important number in the 15CA / 15CB regime is ₹5 lakh per financial year, in aggregate, per remitter. This threshold determines the form path.

• Aggregate ≤ ₹5 lakh in the FY: Only Form 15CA Part A is required. No CA certificate. Self-declaration by the remitter.
• Aggregate > ₹5 lakh in the FY AND chargeable to tax: Form 15CA Part C (most common) + Form 15CB from a CA.
• Aggregate > ₹5 lakh AND a nil-TDS or low-TDS order has been obtained from the AO: Form 15CA Part B (uses the AO order; no CA certificate needed).
• Not chargeable to tax at all (e.g., capital remittance): Form 15CA Part D only.

The threshold is checked on a financial-year cumulative basis per remitter. A company that has already remitted ₹4.5 lakh in the year and is making a fifth remittance of ₹1 lakh has crossed the ₹5 lakh aggregate threshold and must obtain Form 15CB for the fifth remittance (and any further remittance for the rest of the year).

The four parts of Form 15CA

Part A, small remittance, self-declaration. Used when aggregate FY remittances to the same beneficiary are ≤ ₹5 lakh. The remitter declares the nature of the payment, the beneficiary's details, the amount, and the TDS computed by them. No CA certification.

Part B, small remittance with AO order. Used when remittance exceeds ₹5 lakh aggregate but the remitter has obtained a specific order under section 195(2) (determining the tax to be deducted), section 195(3) (NIL certificate for the deductee), or section 197 (lower TDS certificate). The AO order is the basis for the rate.

Part C, large remittance with CA certificate. Used when remittance exceeds ₹5 lakh aggregate, is chargeable to tax, and no AO order has been obtained. The CA certifies the rate of TDS in Form 15CB. This is the most common path for corporate remittances above ₹5 lakh.

Part D, not chargeable to tax. Used when the remittance falls in a category not chargeable to Indian tax (capital account transactions, gifts within LRS limit, etc.). The remitter declares the basis for non-chargeability. No TDS is deducted because none is due.

The four parts are mutually exclusive. The remitter picks one based on the path that matches the remittance.

The 33-item exempt list (Schedule III of Rule 37BB)

For 33 categories of remittances, neither Form 15CA nor Form 15CB is required. Common items:

• Indian investments abroad, in equity, debt, or immovable property
• Remittances for family maintenance and savings (within LRS)
• Remittances for medical treatment abroad
• Remittances for education abroad (tuition, hostel, living)
• Gifts within the LRS limit
• Refund of unutilised travel advance
• Refund of advance against exports
• ECB principal and interest (external commercial borrowing)
• FDI principal and interest
• Specified payments for imports (where the value is below threshold)
• Repatriation of unspent advance to a foreign agent

The 33-item list is enumerated in Rule 37BB. The remitter must match the transaction exactly to a listed category; "approximately fits" is not sufficient. If there is any doubt, the safe default is to file Form 15CA Part A (if small) or Part C with 15CB (if large). The cost of erring on the side of filing is small; the cost of skipping the form when it was required is a section 271-I penalty of ₹1 lakh plus potential FEMA exposure.

What the CA actually certifies in Form 15CB

Form 15CB is a professional certificate, not a clerical exercise. The CA certifies:

1. The nature of the remittance (royalty, fees for technical services, business income, dividend, capital gains, etc.) per the Income-tax Act and the DTAA.
2. The applicable TDS rate, citing the specific section under the Act and the specific article under the DTAA.
3. The basis for the rate selection, including any treaty benefit applied.
4. The amount of TDS to be deducted, with the gross-up calculation if applicable (when the remitter is bearing the TDS).
5. The deductee's TRC (tax residency certificate) and Form 10F (where claimed under DTAA).

The CA's professional liability is meaningful. An incorrect Form 15CB can trigger section 271J penalty (₹10,000 per certificate) plus ICAI disciplinary proceedings. In practice, CAs apply a conservative reading when a treaty benefit is uncertain, which can result in higher TDS than strictly necessary; the deductee then claims refund from the Indian government.

CA fees for Form 15CB typically range from ₹15,000 to ₹50,000 per certificate depending on complexity (a simple royalty remittance with a clear DTAA rate is at the low end; a complex services-with-PE-question remittance is at the high end).

The bank's role

The Authorised Dealer (AD) bank, typically the remitter's primary bank handling the SWIFT, is the gating party. The bank requires:

1. Form 15CA acknowledgment (printed copy from the income tax portal).
2. Form 15CB acknowledgment (printed copy, where applicable).
3. Form A2, the standard outward remittance application form prescribed under FEMA, with details of the beneficiary, amount, purpose code.
4. Underlying documentation, invoice, contract, purchase order, or other primary document justifying the remittance.
5. Beneficiary details, SWIFT BIC, IBAN, beneficiary name and address, beneficiary bank name and address.
6. For DTAA-based reduced TDS, the beneficiary's Tax Residency Certificate (TRC) for the relevant calendar year, plus Form 10F (self-declaration with PAN if available or alternative ID).
7. For services payments, a no-PE (no permanent establishment) declaration from the deductee, where the DTAA article requires the deductee to be without a PE in India to benefit from the lower rate.

The bank's compliance officer reviews these documents. Common rejection reasons: TRC expired (TRCs are usually valid for the calendar year), Form 10F missing or in wrong format, no-PE declaration not signed by an authorised signatory of the deductee, A2 form purpose code does not match the nature of remittance in 15CA / 15CB.

A note on TRC and Form 10F validity

For remittances to a foreign payee where the DTAA rate is claimed, the TRC must be:

• Issued by the tax authority of the deductee's country of residence.
• Valid for the period during which the remittance is made (typically the calendar year of issuance, but the deductee's tax year may differ).
• In English (translated if originally in another language; some banks accept official translations).

Form 10F is filed by the deductee on the Indian income tax portal (since FY 2022-23, Form 10F is filed online, not as a paper declaration to the remitter). The remitter receives the acknowledgment number and includes it in Form 15CA / 15CB.

The CBDT has provided some relief for non-resident deductees without a PAN to file Form 10F manually until the portal-based filing was made compulsory; the practical position has evolved through several CBDT notifications. The current position as of May 2026 is that Form 10F must be filed on the portal; manual Form 10F is no longer accepted by AD banks.

The practical workflow for a typical corporate remittance

For a corporate remittance of, say, USD 25,000 for software licence fees to a US vendor:

1. Determine chargeability and rate. Software licence fee is "royalty" under section 9(1)(vi). India-USA DTAA Article 12 caps the rate at 15 per cent (vs. 20 per cent under the Act). With TRC and Form 10F, the 15 per cent rate applies.

2. Obtain documents from the US vendor. TRC for the relevant year, Form 10F acknowledgment (vendor files on Indian portal), no-PE declaration (signed by the vendor's authorised officer).

3. CA prepares Form 15CB. Certifying royalty nature, 15 per cent DTAA rate, the TRC reference, the no-PE position. CA acknowledgment number is generated.

4. Remitter files Form 15CA Part C. Using the 15CB acknowledgment number, declaring the amount, beneficiary details, TDS at 15 per cent (= USD 3,750 equivalent in INR, computed on the date of credit/payment).

5. Deposit TDS via challan ITNS 281 with code 195 by the 7th of the following month.

6. Submit to bank. The 15CA + 15CB acknowledgments, A2 form, invoice, TRC, Form 10F, no-PE declaration.

7. Bank executes SWIFT. Typically same day or next working day after document verification.

8. Issue Form 16A to the US vendor within 15 days of the relevant TDS return due date (Form 27Q quarterly).

The whole cycle from CA engagement to SWIFT execution typically runs 5-10 working days for a routine remittance, longer when treaty interpretation is non-trivial.

When to consult on this

Three signals that a remittance needs case-by-case CA advice rather than a routine 15CB:

• The nature of the payment is ambiguous (e.g., is it fees for technical services, royalty, business income, or hybrid?).
• The DTAA article includes a PE test or "makes available" test (typical in India-USA, India-UK, India-Singapore for FTS / FIS articles).
• The recipient is in a jurisdiction with no DTAA with India (default rate is 20 per cent + cess + surcharge).

For routine, well-categorised payments, the 15CB cost is bounded and the timing is predictable. For ambiguous payments, the time and cost of a properly-defended position is meaningfully higher but unavoidable; the alternative is a section 201 inquiry from the AO three to five years later, when the cost of remediation is far higher.