Form 15CA and 15CB: Foreign Remittance Certification

What Form 15CA and Form 15CB are

Whenever money is remitted out of India to a non-resident, the Income-tax Act wants to know whether that payment is chargeable to tax in India and, if so, whether tax has been correctly withheld under section 195. Two forms carry that information:

• Form 15CA is a self-declaration filed electronically by the remitter (or their authorised signatory) on the income-tax e-filing portal, stating the nature of the remittance and its tax treatment.
• Form 15CB is a certificate issued by a Chartered Accountant, examining the taxability of the remittance and certifying the correct rate and amount of TDS. It feeds into Part C of Form 15CA — you cannot complete Part C without a valid 15CB reference.

Banks authorised to handle foreign exchange (AD banks) generally will not release an outward remittance without the 15CA acknowledgment — and, where applicable, the underlying 15CB — on file. In practice, this is the single most common reason a foreign payment gets held up at the bank.

The four parts of Form 15CA — which one applies

Form 15CA is not one form with one flow. Depending on the nature of the remittance, you file one of four parts. Getting the part right is the first decision, and it determines whether a CA certificate is even needed.

The threshold figure that separates Part B and Part C cases is commonly cited as ₹5 lakh in aggregate during the financial year, and the list of payments exempt from 15CA altogether (Part D) is a specified list tied to RBI's current-account transaction rules. Both the exact threshold and the specified list are updated from time to time — always verify the current figures on the income-tax e-filing portal before relying on them, especially for a remittance close to the boundary.

What the CA certifies in Form 15CB

When Part C applies, the certifying CA is not rubber-stamping the remitter's stated position. The certificate requires the CA to independently examine and record an opinion on:

• The nature and purpose of the remittance, backed by the underlying agreement or invoice.
• Whether the sum is chargeable to tax in India in the hands of the non-resident recipient, under the Act.
• Whether the recipient is eligible for relief under the applicable Double Taxation Avoidance Agreement (DTAA) — which requires the recipient's Tax Residency Certificate (TRC) and, typically, Form 10F.
• The correct rate and amount of tax to be deducted at source under section 195, factoring in any treaty rate actually claimed.

The CA signs the certificate digitally, and it carries a UDIN generated on the ICAI portal — without a valid UDIN the certificate is treated as invalid for regulatory purposes. Because the certificate is a professional opinion with the CA's name and registration attached, most firms insist on seeing the invoice, the contract, the recipient's TRC/Form 10F, and — where treaty relief is claimed — a no-PE declaration, before signing.

The filing process, step by step

The mechanics run entirely on the income-tax e-filing portal and are broadly the same across financial years, though screens and exact navigation are refreshed periodically — treat the sequence below as the framework, not a screenshot-accurate walkthrough.

1. CA prepares and uploads Form 15CB using their portal login, after independently reviewing the remittance documents. The form generates a unique acknowledgment number.
2. Remitter logs in and fills Form 15CA, selecting the correct part (A/B/C/D). For a Part C filing, the remitter pulls in the CA's 15CB acknowledgment number — the two filings are linked.
3. Remitter submits and e-verifies Form 15CA — typically via digital signature or an OTP-based e-verification — which generates the 15CA acknowledgment.
4. Remitter hands the acknowledgment to the bank along with the remittance application (Form A2) and supporting documents. The AD bank checks the forms are in order before releasing the funds.

Because the bank is usually the one enforcing this sequence in practice, start the 15CA/15CB process a few working days before the payment deadline — a certificate rushed the same day the wire is due to go out is where most errors and delays happen.

Practical notes for a practicing CA

• Don't certify from the invoice alone. Ask for the underlying contract or purchase order — the nature of the remittance (royalty, fee for technical services, reimbursement of actual cost, purchase of goods) changes both taxability and the treaty article that applies.
• TRC and Form 10F are not optional if treaty relief is claimed. Without a valid, current-year TRC from the recipient's home tax authority, the beneficial DTAA rate cannot be applied — fall back to the rate under the Act.
• Reimbursements are a frequent grey area. A pure cost-to-cost reimbursement with no profit element is often argued as not chargeable to tax, but the burden of demonstrating "no mark-up" sits with the remitter — get the cost workings in writing before certifying Part A/D treatment.
• Track the aggregate, not the single remittance. A client making several smaller payments to the same non-resident across the year can cross the Part C threshold in aggregate even if no single payment does — this is a common client-side blind spot.
• Keep the UDIN and working papers together. If the certificate is ever questioned, ICAI and tax authorities will expect to see the analysis that supports the taxability and TDS conclusion, not just the signed form.

For a firm handling remittance certifications for several clients through the year, the practical bottleneck is usually not the analysis — it's tracking which client has a remittance due, which CB has been issued, and which are still pending bank submission. If that tracking currently lives in email threads and a shared spreadsheet, TatvaBooks' Practice plan gives a CA firm one place to see client-wise compliance items and deadlines across the portfolio — worth a look if 15CA/15CB volume is growing. See pricing or book a CA-focused demo.

Frequently asked questions