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NRI · FEMAForm 15CA and 15CB: foreign remittance compliance with examples
Sending money abroad – to a foreign vendor, an NRI seller or your own account from NRO – often needs Form 15CA on the e-filing portal and, above ₹5 lakh, a CA's certificate in Form 15CB. Here is when each part applies, with examples.
Rule 37BB of the Income-tax Rules, 1962 (carried into the 2026 Rules) requires information about payments to non-residents to be furnished in Form 15CA, supported in some cases by a Form 15CB certificate from a chartered accountant. The aim is to ensure TDS under Section 195 (Section 393(2)) is deducted where due.
Which part of 15CA
| Situation | Form |
|---|---|
| Remittance not chargeable to tax in India (e.g. purchase of goods imported, business services where no PE and not FTS under DTAA, after analysis) | Part D |
| Chargeable, aggregate up to ₹5 lakh in the FY | Part A |
| Chargeable, with lower/nil certificate under 195(2)/195(3)/197 | Part B |
| Chargeable, above ₹5 lakh, no certificate | Part C + Form 15CB |
| Specified list in Rule 37BB (e.g. imports of goods, travel, LRS items, gifts by individuals, education, medical) | Not required |
What Form 15CB certifies
- Nature and purpose of remittance (RBI purpose code);
- Taxability under the Income-tax Act and the relevant DTAA (with TRC and Form 10F);
- Applicable rate of TDS and amount deducted;
- Grossing up where tax is borne by the payer.
Process
- Payer (remitter) obtains invoice/agreement, beneficiary's TRC, Form 10F and no-PE declaration where DTAA benefit is claimed.
- CA examines and issues 15CB on the e-filing portal (for Part C).
- Remitter files 15CA online (Part A/B/C/D) and gets an acknowledgement.
- Remitter deducts and deposits TDS, then submits 15CA/15CB to the bank with Form A2.
- Bank remits.
- TDS statement (27Q) is filed quarterly.
Worked examples
Example 1 – software subscription from a US company Example: Pixelgrid Infotech Pvt Ltd pays USD 12,000 (₹10 lakh) for a cloud software licence to a US company. Under domestic law it may be royalty; under the India–US DTAA, payments for copyrighted software (not the copyright) are generally not royalty following the Supreme Court in Engineering Analysis (2021). With TRC and Form 10F, and no PE, it may be not chargeable → Part D (no 15CB) – but many banks still ask for a CA's analysis.
Example 2 – technical consultancy from a UK firm Example: A Delhi manufacturer pays ₹20 lakh to a UK consultant for technical services that "make available" know-how. Under the India–UK DTAA, FTS is taxable at 10% (15% in some cases) with TRC. As it is taxable and above ₹5 lakh → 15CB + Part C, TDS at the DTAA rate (₹2,00,000 at 10%).
Example 3 – NRI repatriating NRO balance Example: An NRI remits ₹30 lakh from her NRO account (sale proceeds of shares on which tax was paid). The bank requires 15CA Part C with 15CB certifying that tax has been paid on the source income. Repatriation is within USD 1 million for the year.
Penalties
Failure to furnish 15CA or furnishing inaccurate information attracts a penalty of ₹1 lakh (old Section 271-I). Non-deduction of TDS leads to disallowance of the expense (100% for non-resident payments) and interest.
Common mistakes
- Treating every foreign payment as needing 15CB (imports of goods are exempt).
- Claiming DTAA benefit without TRC and Form 10F.
- Filing 15CA Part D without a proper taxability analysis.
- Not filing 27Q after remittance.
Key takeaway
Determine taxability first; then choose 15CA Part A, B, C or D, with 15CB for taxable remittances above ₹5 lakh. Keep TRC, Form 10F and analysis on file. Our NRI and cross-border team issues Form 15CB and advises on DTAA withholding.
Official references
Provisions discussed (summaries in our Law Library):
- Income-tax Act, 2025 – Section 393(2) (corresponds to 195): TDS – payments to non-residents
- Income-tax Act, 1961 – Section 195 (corresponds to 393(2)): TDS – payments to non-residents
Official sources to verify the current text, notifications and circulars:
Frequently asked questions
When is Form 15CB required?
When the remittance to a non-resident is chargeable to tax and exceeds ₹5 lakh in a financial year, and no lower/nil deduction certificate or order has been obtained. The CA certifies the taxability and TDS.
What are the four parts of Form 15CA?
Part A – taxable remittances up to ₹5 lakh in a year; Part B – taxable remittances where a certificate/order under Section 195(2)/(3) or 197 is obtained; Part C – taxable remittances above ₹5 lakh with Form 15CB; Part D – remittances not chargeable to tax (other than the specified exempt list).
Is Form 15CA needed for remittances under LRS?
Remittances by individuals under the Liberalised Remittance Scheme that do not require RBI approval, and items in the specified list (Rule 37BB), do not need Form 15CA/15CB.
Who files Form 15CA?
The remitter (payer) – the Indian company, individual or NRI remitting from an NRO account – on the e-filing portal, and submits it to the bank.
Is 15CB needed for payments to foreign vendors for imported goods?
No. Import of goods is in the specified list; 15CA/15CB is not required.
Does 15CA apply to gifts to relatives abroad?
Gifts by individuals under LRS are in the specified list and do not need 15CA/15CB.
Can the CA issue 15CB without TRC?
To apply DTAA rates, TRC and Form 10F are needed. Without them, domestic rates apply.
This article is general information on the law as on 10 November 2026, written for educational purposes. It is not professional advice for your case. Section numbers under the Income-tax Act, 2025 should be confirmed with the official section mapping on the Income Tax Department website before use in filings.
Have a tax, GST or business question?
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