Do I need 15CA and 15CB for paying Google Ads or Meta Ads from India?

Last updated 3 August 2026

Full Answer

A Hyderabad performance marketing agency was spending Rs 12 lakhs per month on Google Ads and Rs 4 lakhs on Meta Ads through their Axis Bank business account. In their fourteenth month of operations, the bank's compliance team ran a routine review of international payment patterns. They found that the agency had been making these payments through auto-debit from a credit card tied to Google's billing, and that no 15CA filings existed for any of the payments. The bank flagged a potential liability of Rs 1.92 crores in cumulative ad spend without documentation.

Ad payments to Google and Meta are among the most common unmanaged compliance exposure points for Indian businesses, particularly agencies, startups, and D2C brands.

Google invoices Indian advertisers through Google Ireland Limited. Meta invoices through Meta Platforms Ireland Limited. Both are Irish entities. Payments from India to Ireland are governed by the India-Ireland DTAA, notified under Section 90 of the Income Tax Act, and by the Act's source-based taxation provisions for non-resident income.

Under Section 9(1)(vii), fees for technical services payable to a non-resident are deemed to accrue or arise in India and are subject to TDS. Indian courts and the Income Tax department have generally treated advertising services, particularly digital advertising involving targeting algorithms and technical infrastructure, as FTS. The TDS rate under the domestic provisions of the Income Tax Act is 10 percent for FTS paid to a non-resident.

The India-Ireland DTAA under Article 12 provides for a 10 percent rate on FTS as well. The treaty rate and the domestic rate are the same in this case, so claiming DTAA benefit does not reduce the TDS obligation. However, to rely on the DTAA at all, you need a Tax Residency Certificate from the Irish entity. Google and Meta do not provide TRCs proactively to Indian advertisers.

Some CA practices take the position that standard programmatic digital advertising, where the advertiser is simply buying impressions or clicks on an automated platform and no specialized technical knowledge is being transferred, is more akin to a purchase of advertising space than FTS. Under this characterisation, TDS would not apply to the foreign entity's income if it has no PE in India. This position has been argued before tribunals and has had mixed outcomes. It is not settled law and adopting it requires a written CA opinion and comfort with the risk.

For practical purposes: if your combined annual spend on Google Ads and Meta Ads crosses Rs 5 lakhs, your bank will ask for 15CA (now Form 145) documentation at some point. Auto-debit credit card payments may not be caught immediately but they are not exempt. Once the bank's system flags cumulative payments to a foreign entity above the threshold, they will require retroactive documentation or will restrict future payments.

The same compliance logic applies across the spectrum of foreign digital platform payments: AWS, Microsoft Azure, and Google Cloud (cloud infrastructure), LinkedIn Ads, Twitter Ads (US entities), Zoom and Microsoft Teams subscriptions, design tools like Figma and Adobe Creative Cloud, and CRM platforms like Salesforce and HubSpot. Each significant foreign vendor relationship above Rs 5 lakhs annually needs a CA to take a position on TDS applicability and issue 15CB accordingly.

The most defensible approach for agencies and startups: maintain a foreign payment tracker by vendor. When any single vendor relationship crosses Rs 4 lakhs in a year, engage a CA for a TDS opinion specific to that vendor's invoice terms and entity structure. File 15CA and 15CB before the next payment goes out. This removes the retroactive scramble and keeps the compliance current.

Note: Rates and thresholds mentioned are as of FY 2024-25. Always verify current figures before acting.

This article is for general information only. For your specific remittance, consult a practicing CA.