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International Tax service

Withholding Tax

Section 394, Form 15CA/CB & treaty rate analysis

Incorrect withholding on cross-border payments attracts interest, disallowance, and treaty disputes. We analyse payment characterisation, applicable rates, and documentation before amounts are remitted.

Withholding support

  • Characterisation of payment — royalty, FTS, interest, or business income
  • Treaty vs statutory rate analysis and beneficial ownership considerations
  • Form 15CA/CB preparation and CA certificate support
  • Lower/nil deduction applications where appropriate
  • Coordination with bankers on remittance compliance

International tax mistakes are expensive and hard to unwind. We advise with conservative, document-backed positions suited to how Indian tax authorities actually examine cross-border cases.

Section 195 (2025: table under section 393(2)) starts with characterisation — royalty, FTS, interest, capital gains, business income — not with a copied 10% rate. Form 15CA Part C needs 15CB; Part D is only for sums not chargeable. See the public chart and Part C vs D guides rather than a WhatsApp summary.

We will not issue 15CB on a missing TRC when you want a treaty rate, and we will not file Part D on a management-fee invoice labelled “reimbursement.”

Read these before you remit

  • /guides/section-195-tds-non-resident — characterisation chart (no invented rates).
  • /guides/form-15ca-part-c-vs-part-d — which 15CA part the bank will accept.
  • /guides/form-15ca-15cb-checklist — document pack.

Discuss your withholding tax requirements

Speak directly with a PJRJ specialist — we respond within one business day.

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