Form 15CB and Form 15CA filing is a key component of managing foreign remittances under Indian tax law. Beyond technical knowledge, it requires a well-defined process, careful documentation, and a clear understanding of both domestic tax provisions and the applicable Double Taxation Avoidance Agreement (DTAA), if any.

This guide outlines a step-by-step process for efficiently managing 15CB certification and 15CA generation, with a focus on standardizing practice-level operations.

1. Pre-Filing Process and Documentation Control

Start by standardizing the intake process with a foreign remittance request form or checklist sent to the client. This ensures you receive all required information upfront, minimizing back-and-forth with the client.

Required documents and information include:

• Invoice or agreement for the transaction

• Remitter and recipient details (legal name, address, PAN if available)

• Nature and purpose of remittance (e.g., royalty, professional services)

• Country of remittance and currency

• Proposed amount and conversion rate (if available)

• TRC (Tax Residency Certificate) from the recipient, Form 10F, and a declaration of beneficial ownership if DTAA benefit is to be claimed

• Copy of the remitter’s TAN, and withholding tax payment challan if already paid

• FEMA purpose code and RBI compliance documentation (if any)

Maintain a digital repository (e.g., client folder structure) for each remittance case to keep source documents organized and accessible.

2. Determining Withholding Tax and Applicability

Before proceeding to Form 15CB, perform a withholding tax analysis:

• Step 1: Classify the income – Determine whether the income is taxable in India under Section 5 or 9 of the Income Tax Act.

• Step 2: Evaluate DTAA benefits – Check whether the DTAA with the recipient's country provides a lower tax rate or excludes the payment from taxation in India.

• Step 3: Apply Section 195 – Identify the applicable rate under Section 195 read with the relevant DTAA article, if conditions are satisfied.

Use internal templates for TDS calculations, referencing rate comparison (IT Act vs. DTAA) and documentation sufficiency (TRC, 10F, declaration of beneficial ownership, etc.).

Document this analysis as part of your working papers. In audit-sensitive categories (e.g., technical services or management fees), ensure internal peer review.

3. Filing Form 15CB on the Income Tax Portal

Form 15CB must be filed using the Chartered Accountant’s login on the Income Tax e-Filing portal.

Step-by-step filing:

1. Log into the Income Tax Portal using the CA login credentials.

2. Navigate to:
   e-File → Income Tax Forms → File Income Tax Forms → Select Form 15CB.

3. Enter the following sections in the form:

   • Remitter details (PAN, address, contact details)

   • Remittee details (name, country, address, PAN if available)

   • Nature of remittance (select from pre-defined dropdowns based on purpose codes)

   • TDS computation including grossing up if applicable

   • DTAA applicability with article reference and justification

   • Challan details if tax has been deposited

4. Attach supporting documents (optional but recommended): invoice, agreement, TRC, etc.

5. Submit using a valid Digital Signature Certificate (DSC).

After submission, an Acknowledgement Number is generated. This is required for completing Form 15CA.

Maintain a signed and stamped PDF copy (digital or scanned) of Form 15CB in the client’s file.

4. Generation and Submission of Form 15CA

Form 15CA is generated from the client’s (remitter’s) login on the same Income Tax portal.

Process:

1. Log in using the remitter’s credentials.

2. Navigate to:
   e-File → Income Tax Forms → File Income Tax Forms → Select Form 15CA.

3. Select Part C if the remittance exceeds ₹5 lakh and is not covered under the exempt list (in which case 15CB is mandatory).

4. Input the Acknowledgement Number of Form 15CB.

5. Fill in:

   • Remitter and remittee details

   • Purpose of remittance

   • Country, currency, and amount

   • TDS rate and tax amount as per 15CB

6. Submit the form using EVC (for individuals) or DSC (for businesses).

A system-generated Form 15CA in PDF format becomes available after submission.

Banks usually require hard copies of both Form 15CA and 15CB, signed and stamped, along with KYC documents.

5. Bank Submission Package and Turnaround

Prepare a consolidated remittance package for the client to submit to the bank, including:

• Form 15CA (signed)

• Form 15CB (CA-signed and stamped)

• Copy of the agreement/invoice

• FEMA purpose code confirmation

• TRC, Form 10F, declaration (if DTAA used)

• Bank’s remittance request form

In cases where tax is not deductible (e.g., exempted payments under Rule 37BB), document the reasoning with a no-TDS note signed by the responsible partner or principal CA.

Some firms automate the final document package generation through internal templates or workflows within practice management tools.

6. Record-Keeping and Risk Management

Maintain detailed digital records of:

• All supporting documents received and relied upon

• Withholding tax computation working papers

• Final signed copies of 15CA and 15CB

• Internal approvals or notes, especially where DTAA positions are taken

Ensure access controls and folder structures are maintained in compliance with the ICAI Code of Ethics and GDPR/DPDP where applicable.

Establish periodic peer reviews for Form 15CB filings involving:

• Royalties

• Technical services

• Business profits under “Permanent Establishment” tests

• Grey-zone DTAA claims

Conclusion

An effective 15CB–15CA filing process is built on more than compliance—it relies on consistency, documentation standards, and efficient coordination between the CA team, the client, and the bank. With clearly defined steps, checklists, and working papers, firms can reduce processing time and minimize exposure to regulatory queries or tax disallowances.