If your Indian company makes royalty or FTS (Fees for Technical Services) payments to a Singapore-based entity, your compliance checklist just changed. Under the Direct Tax Code 2025, effective for Assessment Year 2026-27, the old Form 15CB (Chartered Accountant's certificate for foreign remittances) has been replaced by Form 146. Every internal SOP, vendor agreement, and accounts payable workflow that references "Form 15CB" must now read "Form 146." The underlying DTAA benefit — a reduced 10% withholding rate under the India-Singapore DTAA — remains unchanged.

Who this affects: Indian companies paying royalties, software licensing fees, or FTS to Singapore entities. The compliance burden stays the same; only the form number changes. Missing this update can trigger TDS short-deduction notices.

• DTAA rate for royalties: 10% (vs. 20% + surcharge + cess under Section 115A of the Direct Tax Code 2025)
• Old form: Form 15CB (Income Tax Act, 1961 era)
• New form: Form 146 (Direct Tax Code 2025)
• Effective from: AY 2026-27

What Changed: Form 15CB to Form 146?

Form 15CB was a certificate issued by a Chartered Accountant confirming that the applicable TDS had been deducted before remitting money outside India. The Direct Tax Code 2025 has renumbered and restructured several compliance forms. Form 15CB is now referred to as Form 146 in the new framework. The purpose is identical — a CA-certified declaration that the correct tax has been deducted as per DTAA or domestic provisions — but any filing or process that cited the old form number is now non-compliant if it has not been updated.

Similarly, the associated declarant form (previously Form 15CA) has also been renumbered under DTC 2025. Always confirm with your CA which new form number corresponds to your specific remittance category before filing.

What is the Royalty Tax Rate Under India-Singapore DTAA?

Under the India-Singapore Double Taxation Avoidance Agreement (DTAA), royalties and FTS paid to a Singapore tax resident are taxable at 10% — significantly lower than the default Section 115A rate of 20% plus applicable surcharge and cess. To claim this benefit, the Singapore entity must provide a valid Tax Residency Certificate (TRC) and Form 10F. Without these, the payer must deduct TDS at the higher domestic rate.

Provision	Rate (Royalty / FTS)	When Applicable
Section 115A – Direct Tax Code 2025	20% + Surcharge + Cess	No DTAA benefit claimed
India-Singapore DTAA	10%	Valid TRC + Form 10F + No-PE Declaration submitted

Updated Singapore Royalty Payment Checklist (2026)

As of July 2026, this is the complete revised checklist for Indian entities remitting royalties or FTS to Singapore. Update every reference of "Form 15CB" in your internal documents to "Form 146".

Documents Required from the Singapore Entity

• Tax Residency Certificate (TRC) — issued by the Inland Revenue Authority of Singapore (IRAS), confirming Singapore tax residency for the relevant year
• Form 10F — self-declaration by the Singapore entity (as required under Indian tax law) covering name, status, nationality, PAN (if any), period of TRC validity, and address
• No Permanent Establishment (No-PE) Declaration — a declaration by the Singapore entity that it does not have a permanent establishment in India
• PAN card (if the Singapore entity has one, or needs to file ITR in India in the future)
• DSC of Foreign Signatory — a Digital Signature Certificate of the authorised signatory of the Singapore company is required for income tax filings in India (a regular director's DSC alone is not sufficient; an organisational DSC linked to the foreign entity is needed)

Documents Prepared by the Indian Payer

• Form 146 (previously Form 15CB) — a certificate from a practising Chartered Accountant confirming that TDS has been correctly deducted as per applicable DTAA or DTC 2025 provisions before the remittance
• Income Tax Login of the Foreign Company — the Singapore entity must have an active income tax login on the Indian income tax portal; this requires a PAN to be applied for first
• TDS Return Filing — the Indian company must deposit deducted TDS and file TDS returns (Form 27Q) reflecting the Singapore entity's details and applicable DTAA rate
• Bank Remittance Form / A2 Form — submitted to the authorised dealer bank along with Form 146 (DTC 2025 equivalent)

When is ITR Filing Mandatory for the Singapore Entity?

If the Singapore entity opts to claim the benefit of the India-Singapore DTAA (i.e., the reduced 10% rate), it is required to file an Income Tax Return in India for that financial year. However, if it accepts taxation under Section 115A at 20% + surcharge + cess and does not claim any DTAA benefit, filing an ITR is not mandatory. Most Singapore entities prefer DTAA rates, making ITR filing a standard compliance step.

DSC Requirements for the Singapore Entity's Signatory

One of the most frequently overlooked compliance steps is obtaining the correct Digital Signature Certificate for the Singapore entity's authorised signatory. A regular director-level DSC or an Indian DSC of a resident director is not sufficient when filing on behalf of the foreign company. An organisational DSC linked to the foreign company is required.

To obtain a DSC for a Singapore-based foreign individual, the following documents and steps are needed:

• Email OTP and phone OTP from the foreign individual
• Video verification of the foreign individual
• Address proof (e.g., driving licence, utility bill)
• Recent passport-size photograph
• Copy of valid passport

Taxocity's compliance team regularly assists Singapore-based companies in completing this process remotely, without the director needing to be physically present in India.

Section 115A vs. DTAA: Which Rate Should You Use?

The choice between Section 115A (domestic law) and the DTAA rate depends entirely on whether the Singapore entity has furnished the required documents. Here is a side-by-side comparison to help Indian payers decide:

Criteria	Section 115A (DTC 2025)	India-Singapore DTAA
TDS Rate on Royalty / FTS	20% + Surcharge + Cess	10%
TRC Required?	No	Yes
Form 10F Required?	No	Yes
No-PE Declaration Required?	No	Yes
ITR Filing for Singapore Entity?	Not mandatory	Mandatory if DTAA claimed
Form 146 (ex-Form 15CB) Required?	Yes (for remittance)	Yes (for remittance)
Net Tax Saving on ₹1 Crore Payment	—	Approx. ₹10–12 lakhs vs. Section 115A

How to Process Singapore Royalty Payment in 2026

Follow these steps in order to ensure full compliance when remitting royalties or FTS to a Singapore company:

1. Collect TRC and Form 10F from the Singapore entity before initiating any payment.
2. Obtain No-PE Declaration signed by the authorised signatory of the Singapore entity.
3. Apply for PAN for the Singapore entity in India if it does not already have one (required for income tax login and ITR filing).
4. Create Income Tax Login for the Singapore entity on the Indian income tax e-filing portal using its PAN.
5. Obtain Organisational DSC of the foreign signatory of the Singapore company (not an individual director's DSC) for income tax filings.
6. Engage a CA to issue Form 146 (the DTC 2025 replacement of Form 15CB) certifying correct TDS deduction.
7. Deduct TDS at 10% (DTAA rate) or 20% + surcharge + cess (Section 115A) as applicable.
8. File TDS Return (Form 27Q) and deposit TDS with the government within due dates.
9. File ITR in India for the Singapore entity if DTAA benefit has been claimed.
10. Remit payment to the Singapore entity after completing all the above steps.

Common Mistakes to Avoid in 2026

• Using "Form 15CB" in filings or correspondence after the Direct Tax Code 2025 came into effect — update all references to Form 146 immediately.
• Accepting an expired TRC — the TRC must be valid for the financial year in which the payment is made.
• Using an individual DSC instead of an organisational DSC for the foreign company's income tax filings in India.
• Not filing ITR for the Singapore entity after claiming DTAA benefit — this is a mandatory compliance step and attracts penalties.
• Late TDS deposit — interest under DTC 2025 applies from the date on which TDS was deductible.

How Taxocity Helps with Singapore DTAA Compliance

Taxocity has been handling cross-border tax compliance for over three decades. Our DTAA compliance team manages the entire workflow — from collecting documents from the Singapore entity, applying for PAN, creating income tax logins, obtaining the organisational DSC for foreign signatories, issuing Form 146 (ex-Form 15CB), filing TDS returns, and filing the Singapore entity's ITR in India.

We offer a 100% compliance guarantee with real human experts at every step. Whether you are making a one-time software licensing payment or ongoing royalty transfers to a Singapore entity, our end-to-end support ensures you never miss a filing or face a short-deduction notice.

Explore related services:

• Form 15CA/15CB (Form 146) for Singapore Royalty Payments
• Form 10F Requirement for Singapore-India DTAA
• GST Registration
• Private Limited Company Registration

Key Takeaways

1. Under the Direct Tax Code 2025 (AY 2026-27), Form 15CB is replaced by Form 146 — update all internal checklists immediately.
2. The India-Singapore DTAA royalty rate remains 10%, compared to 20% + surcharge + cess under Section 115A.
3. Claiming DTAA benefit makes ITR filing in India mandatory for the Singapore entity.
4. An organisational DSC of the foreign signatory is required; a regular director's DSC is not sufficient.
5. The Singapore entity must have a PAN and income tax login in India before ITR can be filed.
6. TRC, Form 10F, and a No-PE Declaration must all be in place before the remittance is made.

Disclaimer

This article is for general informational purposes only and does not constitute tax advice. Tax laws and regulations are subject to change; the information provided here reflects the position as of August 2026. Readers should consult a qualified tax advisor or chartered accountant for advice specific to their circumstances before making any tax or compliance decisions.