When an Indian company makes a royalty payment to a Singapore-based entity, Form 15CA and Form 15CB are mandatory under Section 195 of the Income Tax Act before the remittance is processed by any authorized bank. These forms apply to all foreign remittances that are taxable in India. Under the India-Singapore DTAA, the royalty tax rate is capped at 10%, which is lower than the 20% rate under Section 115A. However, to claim this DTAA benefit, the Singapore entity must provide a Tax Residency Certificate (TRC), Form 10F, a No PE Declaration, a valid PAN, and a DSC of the authorised foreign signatory. Without these, TDS is deducted at 20% plus surcharge and cess.

What Are Form 15CA and 15CB?

Form 15CA is a self-declaration by the remitter (the Indian payer) confirming that applicable tax has been deducted before making a foreign payment. Form 15CB is a certificate issued by a Chartered Accountant verifying the nature of the remittance, applicable tax treaty provisions, and the rate at which TDS has been deducted.

Together, these two forms create an audit trail for the Income Tax Department on cross-border payments, ensuring taxes are not evaded through overseas remittances.

Who Must File These Forms?

• Any Indian resident (individual, company, LLP, or firm) making a payment to a foreign entity that is taxable in India
• Payments for royalties, fees for technical services (FTS), interest, dividends, or any other income chargeable to tax in India
• Payments above ₹5 lakh in a financial year where income is taxable (Form 15CB is required before Form 15CA Part C is filed)

When Are They Required for Singapore Royalty Payments?

Royalty payments to a Singapore entity are among the most common cross-border payments that trigger the Form 15CA/15CB requirement. These include payments for software licenses, patents, trademarks, copyrights, and know-how transferred from Singapore to India.

Scenario	Form 15CA Required?	Form 15CB Required?
Royalty payment above ₹5 lakh (taxable)	Yes (Part C)	Yes
Royalty payment below ₹5 lakh (taxable)	Yes (Part B)	No
Royalty payment exempt under DTAA (with full documentation)	Yes (Part A or B)	May still be required
Payment specifically exempt (listed in Rule 37BB)	No	No

Royalty payments to Singapore do not fall under the Rule 37BB exemption list and are therefore always subject to Form 15CA/15CB compliance.

India-Singapore DTAA: Royalty Tax Rates

Under the India-Singapore Double Tax Avoidance Agreement (DTAA), the tax rate on royalties is 10%. This is significantly lower than the domestic rate of 20% under Section 115A of the Direct Tax Code 2025 (plus surcharge and cess).

To apply the 10% DTAA rate instead of the 20% Section 115A rate, the Singapore entity must submit all mandatory DTAA compliance documents to the Indian payer before the remittance is made.

TDS Rates at a Glance

Provision	Applicable Rate
Section 115A (without DTAA benefit)	20% + Surcharge + Cess
India-Singapore DTAA (Article on Royalties)	10%

Documents Required from the Singapore Entity

For the Indian payer to apply the beneficial DTAA rate of 10% and correctly complete Form 15CB, the Singapore company must provide the following:

• Tax Residency Certificate (TRC): Issued by the Inland Revenue Authority of Singapore (IRAS), confirming that the entity is a tax resident of Singapore
• Form 10F: A self-declaration filed by the foreign entity with Indian tax authorities (can be filed online on the Income Tax portal)
• No Permanent Establishment (PE) Declaration: A declaration that the Singapore entity does not have a PE in India, ensuring the income is not attributable to India
• PAN Card: The Singapore entity must obtain an Indian Permanent Account Number (PAN) to enable ITR filing, if needed
• Income Tax Login: The foreign entity needs an Income Tax India portal login, which requires a PAN
• DSC of Authorised Foreign Signatory: A valid Digital Signature Certificate (DSC) of the authorised signatory of the Singapore company is mandatory for filing Form 10F and ITR online

To obtain a foreign individual's DSC, the following is needed:

• Email OTP and phone OTP from the foreign individual
• Video verification of the foreign individual
• Address proof (such as a driving licence)
• Photograph
• Copy of passport

Step-by-Step Process to File Form 15CA and 15CB (2026)

1. Collect DTAA documents: Obtain TRC, Form 10F, No PE Declaration, and PAN from the Singapore entity
2. Engage a CA for Form 15CB: A Chartered Accountant reviews the nature of payment, applicable treaty provisions, and certifies the correct TDS rate
3. File Form 15CB online: The CA files Form 15CB on the Income Tax e-filing portal and generates an acknowledgement number
4. File Form 15CA Part C: Using the Form 15CB acknowledgement number, the Indian remitter files Form 15CA Part C on the Income Tax portal
5. Submit to the bank: Provide a copy of Form 15CA and Form 15CB to your authorised dealer bank before initiating the foreign remittance (wire transfer/SWIFT)
6. Deduct and deposit TDS: Deduct TDS at 10% (under DTAA) or 20% + surcharge + cess (under Section 115A) and deposit it using Challan 281 before the due date
7. File TDS return (Form 27Q): Report the TDS on foreign payments in Form 27Q quarterly

Due dates for TDS deposit: For individuals, TDS must be deposited by the 30th of the following month (7th for non-government deductors for most months). For other than individuals (companies, LLPs), the same schedule applies with a 7th-of-next-month deadline, except for March where the deadline is 30th April.

What If the Singapore Entity Does Not Provide DTAA Documents?

If the Singapore entity fails to submit the TRC, Form 10F, No PE Declaration, or PAN, the Indian payer cannot apply the DTAA rate. In such cases:

• TDS must be deducted at 20% + applicable surcharge + 4% cess under Section 115A of the Direct Tax Code 2025
• The Singapore entity may claim a refund by filing an ITR in India for the excess TDS deducted
• To file an ITR in India, the Singapore entity must have a PAN, an Income Tax India login, and a valid DSC of its authorised signatory

It is therefore in the interest of both parties to ensure DTAA documentation is in place before the remittance to avoid excess withholding and complex refund processes.

ITR Filing Obligation for the Singapore Entity

Under Section 115A, if the Singapore entity has paid tax without claiming DTAA benefits, it does not need to file an ITR in India. However, if the Singapore entity claims the lower DTAA rate of 10%, it is mandatory to file an ITR in India for that financial year.

To file the ITR, the Singapore entity needs:

• PAN card registered in India
• Active Income Tax India portal login
• DSC of the authorised foreign signatory

See our detailed guide on Form 10F requirements for Singapore-India DTAA royalty payments for a complete walkthrough.

How Taxocity Helps with Singapore Royalty Remittances

Taxocity, with over three decades of experience in Indian tax and compliance, offers end-to-end support for cross-border royalty payment compliance, including:

• Obtaining PAN for foreign entities and setting up their Income Tax India login
• Assisting with foreign DSC procurement (including video verification for Singapore signatories)
• Filing Form 10F, Form 15CB, and Form 15CA
• Advising on DTAA applicability and the optimum withholding rate
• Filing quarterly TDS returns (Form 27Q) and annual ITR for foreign companies in India

With a 100% compliance guarantee and a team of real human experts, Taxocity ensures your international remittances are fully compliant with Indian tax law. Rated 4.8/5 from over 5,000 reviews.

Related services that may be relevant:

• Form 10F for Singapore Royalty Payments
• Form 10F for UAE Royalty Payments
• Form 10F for Switzerland Royalty Payments

Key Takeaways

• Form 15CA (Part C) and Form 15CB are mandatory for taxable royalty payments above ₹5 lakh to a Singapore entity
• Under India-Singapore DTAA, the royalty withholding tax rate is 10%; without DTAA documents, it rises to 20% + surcharge + cess under Section 115A
• The Singapore entity must provide TRC, Form 10F, No PE Declaration, PAN, an Income Tax India login, and an organisational DSC
• If DTAA benefit is claimed, the Singapore entity must file an ITR in India
• A regular director's DSC will not work; an organisational DSC of the foreign authorised signatory is specifically required
• Taxocity provides complete end-to-end support for cross-border royalty compliance

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Disclaimer: The information provided in this article is for general informational purposes only and does not constitute tax, legal, or financial advice. Tax laws and DTAA provisions are subject to change. Please consult a qualified tax advisor or chartered accountant before making any decisions based on this content.