When to use S0902
Use S0902 for money paid abroad: royalty / licence fee for use of originals, patents, copyrights, trademarks. It sits under RBI head 09, royalties, licences and franchises.
Choose the code for what you are buying. The code decides the tax nature below, so a wrong code can mean the wrong rate of tax or a missing Form 145.
The same purpose in the other direction is P0902: Royalty / licence fee received for use of originals, patents, copyrights, trademarks (money received).
Form A1 or Form A2
Form A2: the application for every payment abroad other than for goods imported into India. With it go the invoice, the agreement or purchase order and, unless the code is on the specified list, the Form 145 acknowledgement (and Form 146 for Part C).
Income tax
Royalty. Paid by a resident, it is treated as arising in India wherever the right is used, so tax is withheld under section 393(2) of the Income-tax Act, 2025 (formerly section 195): 20% plus surcharge and 4% cess (20.8% when there is no surcharge) under the Act, or the lower treaty rate when the payee gives a tax residency certificate (TRC) and Form 41 (formerly Form 10F).
Form 145 / 146: Part A up to ₹5 lakh paid to the payee in the year; above it Part C with a CA's Form 146 (or Part B with a tax officer's certificate).
| Payee country | Royalty | Technical fees |
|---|---|---|
| United States | 15% (Art. 12) | 15% (Art. 12) · make-available test |
| United Kingdom | 15% (Art. 13) | 15% (Art. 13) · make-available test |
| Singapore | 10% (Art. 12) | 10% (Art. 12) · make-available test |
| United Arab Emirates | 10% (Art. 12) | No article: business profits |
| Germany | 10% (Art. 12) | 10% (Art. 12) |
| Netherlands | 10% (Art. 12) | 10% (Art. 12) |
| Japan | 10% (Art. 12) | 10% (Art. 12) |
| Australia | 15% (Art. 12) | 15% (Art. 12) · make-available test |
| Canada | 15% (Art. 12) | 15% (Art. 12) · make-available test |
| France | 10% (Art. 13) | 10% (Art. 13) |
Starting figures from FxLayer's treaty table, with the TRC and Form 41 on file. Treaty texts and protocols change; your CA confirms the rate for each country before you pay.
GST
IGST at 18% under reverse charge: the business in India that imports the service pays it in its own GST return (Notification 10/2017-Integrated Tax (Rate), entry 1) and takes the credit where it is eligible.
Reporting and closure
The bank reports the payment under its code. FxLayer keeps the invoice, the Form 145 / 146 acknowledgements and the treaty papers on the payment, so the request goes to the bank complete.
Questions
Guides
General information on RBI purpose codes and the FEMA, income-tax and GST rules as they stood on 14 October 2026. It is not legal or tax advice: confirm the position for your payment with your AD bank or your chartered accountant before acting.
