Form 15CA and 15CB Explained: Which Part Applies to a Foreign Remittance?

Form 15CA and Form 15CB are often spoken about together, but they do different jobs. Form 15CA is the remitter's information statement for specified payments to a non-resident or foreign company, while Form 15CB is a Chartered Accountant's tax-determination certificate required in specified taxable-remittance cases. The practical question is therefore not simply whether a foreign payment is being made, but which reporting route applies to that payment.

The Income Tax Department's Form 15CA user manual divides Form 15CA into four parts based mainly on chargeability, the aggregate remittance amount during the financial year, and whether an Assessing Officer order or a CA certificate is available. Its Form 15CB user manual explains when the CA certificate is required and what the CA certifies.

What is the difference between Form 15CA and Form 15CB?

Form 15CA is filed by the person responsible for the remittance. The Department describes it as information to be furnished for payments to a non-resident, not being a company, or to a foreign company. It is filed for each applicable remittance before the amount is remitted.

Form 15CB is an accountant's certificate. In the cases covered by the current portal guidance, a CA examines the nature of the remittance, chargeability, applicable tax provisions, DTAA relief where relevant, and TDS rate and deduction. Form 15CB is then used for Form 15CA Part C.

Which part of Form 15CA applies?

• Part A: where the remittance or aggregate of such remittances is chargeable to tax and does not exceed ₹5 lakh during the financial year.
• Part B: where the remittance is chargeable to tax, the aggregate exceeds ₹5 lakh during the financial year, and an order or certificate under section 195(2), 195(3) or 197 has been obtained from the Assessing Officer under the 1961 Act framework.
• Part C: where the remittance is chargeable to tax, the aggregate exceeds ₹5 lakh during the financial year, and a certificate in Form 15CB from an accountant has been obtained.
• Part D: where the remittance is not chargeable to tax.

This four-part structure is set out in the Department's official Form 15CA guidance. The ₹5 lakh test is an aggregate financial-year test for the relevant remittances, so reviewing only the current invoice can produce the wrong part selection.

When is Form 15CB required?

The Department's current Form 15CB guidance states that Form 15CB is required for a payment to a non-resident, not being a company, or a foreign company where the payment is taxable and the payment or aggregate of such payments exceeds ₹5 lakh during the financial year, in the Part C situation. The CA certificate must be filed before Form 15CA Part C because the remitter needs the Form 15CB acknowledgement number while completing Part C.

A common mistake is to treat Form 15CB as mandatory for every overseas remittance. That is too broad. The first question is chargeability to tax in India, followed by the amount and the applicable Part A, B, C or D route.

What does the CA examine in Form 15CB?

The Form 15CB workflow includes recipient details, remittance details, taxability under domestic income-tax law, taxability after DTAA relief where applicable, and accountant details. This is why a Form 15CB engagement is not merely a portal-upload exercise. The CA needs enough facts and documentation to determine the character of the payment and the withholding position.

For a treaty claim, the professional review may need to consider the relevant DTAA article, the recipient's tax-residence evidence, beneficial-ownership or other treaty conditions where material, and whether domestic law or treaty provisions produce the applicable result. The exact documentation depends on the transaction and should not be reduced to a universal checklist.

Practical decision framework

1. Identify the payee: confirm that the payment is to a non-resident or foreign company and capture the correct legal identity and country.
2. Identify the nature of payment: for example, professional fees, royalty, interest, software-related payment, reimbursement, purchase consideration or another category. Do not decide taxability from the invoice label alone.
3. Determine chargeability in India: analyse the applicable domestic-law charging and deeming provisions and then any DTAA relief that can validly be claimed.
4. Check aggregate remittances for the financial year: the ₹5 lakh distinction in the current Form 15CA framework uses the remittance or aggregate of remittances during the financial year.
5. Check for an AO order or certificate: where the amount exceeds ₹5 lakh and the remittance is chargeable, an applicable AO order or certificate can point to Part B; otherwise the Part C and Form 15CB route may apply.
6. File in the correct sequence: for Part C, the CA files Form 15CB first and the remitter then uses its acknowledgement number in Form 15CA.
7. Preserve the file: retain the agreement, invoice, taxability note, treaty support, withholding computation, filed forms and acknowledgement details.

Worked examples

Example 1: taxable remittance within ₹5 lakh

Assume an Indian business has a taxable remittance to a non-resident and its aggregate relevant remittances during the financial year do not exceed ₹5 lakh. Under the current Form 15CA structure, Part A is the relevant branch. The ₹5 lakh threshold does not by itself make the payment non-taxable; it determines the reporting branch after chargeability has been established.

Example 2: taxable remittance above ₹5 lakh without AO certificate

Assume the aggregate taxable remittance exceeds ₹5 lakh and no applicable order or certificate from the Assessing Officer has been obtained. Under the current portal guidance, the Part C route applies and Form 15CB must be filed first by the CA. The remitter then enters the Form 15CB acknowledgement number in Form 15CA Part C.

Example 3: remittance not chargeable to tax

If the remittance is not chargeable to tax and the transaction falls within the reporting framework, Part D is the branch identified by the Department's Form 15CA manual. The conclusion that a payment is not chargeable should be supported by a reasoned analysis rather than assumed merely because the payment is made outside India.

How the 2025 Act changes the form numbers

Professionals also need to distinguish the old and new statutory frameworks. The Income Tax Department's Income Tax Forms FAQ states that under the Income-tax Act, 2025, the corresponding provision is section 397(3)(d), and the corresponding forms are Form 145 for old Form 15CA and Form 146 for old Form 15CB. The correct form therefore depends on the period and statutory framework governing the remittance; old form numbers should not be applied mechanically to every post-April-2026 transaction.

Common mistakes to avoid

• Assuming every foreign remittance requires Form 15CB.
• Checking only the current remittance instead of the aggregate during the financial year for the ₹5 lakh branch test.
• Filing Part C before the CA has successfully filed Form 15CB and generated its acknowledgement.
• Treating the bank's documentation request as a substitute for the underlying taxability analysis.
• Claiming DTAA relief without collecting the facts and documents needed to support the treaty position.
• Using old Form 15CA/15CB terminology without checking whether the Income-tax Act, 1961 or Income-tax Act, 2025 framework governs the transaction.

Practical takeaway

Form 15CA is the remitter's reporting form; Form 15CB is the CA's tax-determination certificate for specified Part C cases. Start with the nature and chargeability of the remittance, then test the ₹5 lakh aggregate threshold and whether an AO order or certificate exists. For Part C, file Form 15CB first. For transactions governed by the Income-tax Act, 2025, also check the Department's new Form 145 and Form 146 framework instead of assuming the legacy form numbers continue unchanged.