CORAA

Form 67 Working Paper — Foreign Tax Credit (Section 90/91, Rule 128)

Foreign tax paid and the Indian tax attributable to that same income, laid out side by side per source — the difference computed so it's obvious at a glance which figure is the lower one Rule 128 requires you to claim.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Statutory basis
Section 90/91, Rule 128
Core rule
FTC = lower of foreign tax paid and Indian tax on that income, per source
Filed as
Form 67, on or before the return due date
Evidence needed
Foreign tax certificate + TRC or foreign return acknowledgement
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FOREIGN TAX CREDIT WORKING PAPER — FORM 67 (RULE 128)

Assessee: ___ · PAN: ___ · Previous year ended: ___ · Assessment Year: ___

Purpose: to work out, source by source, the foreign tax credit available under Section 90 (DTAA country) or Section 91 (non-DTAA country) read with Rule 128, and to support the figures that go into Form 67, filed electronically on or before the due date for filing the return of income.

Reading the last column: a POSITIVE figure means the Indian tax attributable to that income exceeds the foreign tax paid — the foreign tax credit for that source is capped at the foreign tax paid (the lower figure). A NEGATIVE figure means the foreign tax paid exceeds the Indian tax attributable — the credit is capped at the Indian tax figure instead (again, the lower of the two). Rule 128(1) allows credit only up to the lower amount, source by source; excess foreign tax over the Indian tax attributable is not creditable or refundable.

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This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

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Common questions

FAQs.

Is Form 67 required even if the DTAA already exempts the income?
Form 67 is specifically for claiming foreign tax credit against Indian tax on income that is taxed in both countries (or taxed abroad and includible in Indian total income). If the DTAA exempts the income from Indian tax entirely, there is no double taxation to relieve and no FTC claim to make on that income — check the relevant DTAA article first, since exemption and credit are two different reliefs.
What happens if Form 67 is filed after the return of income?
Courts and appellate authorities have in several cases treated the Form 67 filing requirement as directory rather than mandatory, allowing FTC even where the form was filed after the due date but before the return was processed — but this is contested and fact-specific, not a settled safe harbour; file Form 67 before or with the return wherever possible rather than relying on this.
Can foreign tax credit be carried forward if it exceeds the year's Indian tax liability?
No — unlike a business loss, unutilised foreign tax credit for a year is generally not available for carry-forward to a later year under the current FTC rules; excess foreign tax paid over the Indian tax attributable to that income in the year it accrues is simply not creditable, which is why matching the timing of income recognition across both countries matters.
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