Form 145 and Form 146

Form 145 and Form 146 vs Form 15CA and Form 15CB: What Changed From 1 April 2026?

India’s foreign-remittance tax reporting framework changed from 1 April 2026 following the commencement of the Income Tax Act, 2025 and Income Tax Rules, 2026.

For remittances made on or after 1 April 2026, taxpayers should now become familiar with Form 145 and Form 146.

In simple terms:

• Form 145 is the new equivalent of Form 15CA
• Form 146 is the new equivalent of Form 15CB

The Income Tax Department has specifically confirmed this transition. Form 145 continues the information-reporting framework for specified payments to non-residents or foreign companies, while Form 146 is the corresponding Chartered Accountant certificate in applicable cases.

Therefore, Indian businesses, individuals, NRIs and other remitters making payments outside India should no longer automatically ask their bank or Chartered Accountant for “15CA/15CB” without first considering the date of remittance and applicable tax framework.

For professional assistance with foreign remittance certification and filing, refer to our Form 145 and Form 146 Filing Services in India.

What Changed From 1 April 2026?

The principal change is the transition from the earlier Income-tax Act, 1961 framework to the Income Tax Act, 2025 framework for remittances made from 1 April 2026.

Form 15CA Became Form 145

Under the earlier framework, Form 15CA was used for furnishing prescribed information relating to certain payments to non-residents.

Under the new framework, the corresponding form is Form 145.

Form 15CB Became Form 146

The earlier Chartered Accountant certificate in Form 15CB has been replaced by Form 146 under the new framework.

New Forms Apply From 1 April 2026

The Income Tax Department has clarified that remittances made on or after 1 April 2026 are governed procedurally by the new Act and Forms 145 and 146.

Form 145 vs Form 15CA

Form 145 performs broadly the role previously associated with Form 15CA, but under the new statutory framework.

Form Number Has Changed

The most visible change is:

Earlier: Form 15CA
From 1 April 2026: Form 145

Purpose Continues

Form 145 furnishes information relating to specified payments to a non-resident, not being a company, or to a foreign company.

The official Income Tax portal describes Form 145 as the new form replacing old Form 15CA for foreign payments.

Filing Takes Place Before Remittance

Form 145 is required to be furnished for each applicable remittance before the amount is remitted.

Remitter Files Form 145

The obligation to furnish Form 145 rests with the person responsible for making the applicable foreign payment.

Form 146 vs Form 15CB

Form 146 is the corresponding Chartered Accountant certification under the new framework.

Form Number Has Changed

Earlier: Form 15CB
From 1 April 2026: Form 146

Chartered Accountant Issues Form 146

Form 146 is a certificate from an accountant in relation to applicable payments to a non-resident or foreign company.

The Income Tax Department’s current forms download page describes Form 146 as the certificate of an accountant for payments to a non-resident or foreign company.

Taxability Is Examined

Before issuing the certificate, the tax position of the remittance needs to be examined.

This may involve consideration of:

• nature of payment;
• taxability in India;
• applicable withholding tax;
• relevant DTAA;
• tax residency documentation;
• Permanent Establishment implications;
• beneficial ownership, where relevant; and
• supporting agreements and invoices.

Form 146 Is Not Required for Every Foreign Remittance

A CA certificate is relevant only in prescribed circumstances.

Therefore, businesses should not assume that every overseas payment automatically requires Form 146.

Form 145 and 146 vs Form 15CA and 15CB – Quick Comparison

The transition can be understood easily as follows.

Information Form

Up to 31 March 2026: Form 15CA
From 1 April 2026: Form 145

CA Certificate

Up to 31 March 2026: Form 15CB
From 1 April 2026: Form 146

Governing Framework

Earlier: Income-tax Act, 1961 and corresponding rules

New: Income Tax Act, 2025 and Income Tax Rules, 2026 for applicable remittances from 1 April 2026.

Basic Objective

The fundamental objective continues to be reporting specified foreign remittances and ensuring appropriate consideration of withholding-tax requirements.

The Income Tax Department has stated that the substantive requirements relating to remittance information, CA certification above the prescribed threshold in applicable cases and TDS compliance broadly continue under the new system.

What Is Form 145?

Form 145 is the prescribed information form under the new foreign-remittance reporting framework.

Who Uses Form 145?

The Income Tax Department states that taxpayers, authorised signatories and representative assessees can use Form 145 for furnishing information regarding applicable payments to a non-resident or foreign company.

When Is Form 145 Filed?

Form 145 is filed before making the applicable remittance.

Is One Form Enough for Multiple Remittances?

The official portal states that Form 145 is furnished for each applicable remittance.

Businesses making recurring overseas payments should therefore review compliance for each remittance rather than treating an earlier filing as a blanket certification for future payments.

What Are the Four Parts of Form 145?

Form 145 continues with a four-part structure.

The correct part depends upon factors including taxability, amount and whether an Assessing Officer certificate or Form 146 has been obtained.

Part A of Form 145

Part A applies where the remittance is taxable under the Act and the remittance or aggregate of such remittances does not exceed ₹5 lakh during the tax year.

Part B of Form 145

Part B applies where the remittance is taxable, exceeds ₹5 lakh during the tax year and the prescribed certificate from the Assessing Officer has been obtained.

Part C of Form 145

Part C applies where the remittance is taxable, exceeds ₹5 lakh during the tax year and a Chartered Accountant certificate in Form 146 has been obtained.

Part D of Form 145

Part D broadly deals with remittances not taxable under the Act, subject to the exclusions specified under the applicable rules.

The exact part should be selected after examining the facts and current statutory requirements rather than merely by looking at the amount of the remittance.

What Is Form 146?

Form 146 is the Chartered Accountant certificate used in specified foreign-remittance cases.

Form 146 Replaces Form 15CB

Businesses familiar with the old system can broadly understand Form 146 as the successor to Form 15CB.

CA Examines the Transaction

The Chartered Accountant needs to understand the underlying transaction before determining the appropriate certification.

Supporting Documents Are Important

The certification should be based on the actual transaction documents rather than only the amount appearing in the bank-remittance request.

When Is Form 146 Required?

A common misconception is that a CA certificate is required whenever money is sent abroad.

That is not correct.

Taxability Matters

The first question is whether the payment is taxable in India.

₹5 Lakh Threshold Matters

For taxable remittances exceeding the prescribed ₹5 lakh threshold during the tax year, Form 146 becomes relevant where the remitter is proceeding through the CA-certification route for Part C of Form 145.

AO Certificate Can Change the Requirement

Where the prescribed Assessing Officer certificate has been obtained, Part B may apply instead of Part C.

The Income Tax Department specifically identifies removal of duplication in this situation as a feature of the new framework.

Is Form 146 Required for Every Foreign Payment Above ₹5 Lakh?

No.

The amount alone does not determine whether Form 146 is required.

Taxability Must Be Determined First

A payment exceeding ₹5 lakh should not automatically be treated as requiring Form 146 without analysing its taxability and the applicable rules.

Nature of Remittance Matters

Different tax consequences can arise for:

• services;
• royalty;
• interest;
• commission;
• software payments;
• reimbursement;
• import transactions;
• professional fees;
• technical fees;
• dividend;
• property-related remittances; and
• other overseas payments.

DTAA May Affect the Tax Position

Where the recipient is eligible for treaty benefits, the applicable Double Taxation Avoidance Agreement may affect the withholding-tax analysis.

Are Old Form 15CA and Form 15CB Still Valid?

This is particularly important during the 2026 transition.

Forms Filed for Pre-1 April 2026 Remittances

The Income Tax Department has clarified that Forms 15CA and 15CB already submitted for remittances made before 31 March 2026 continue to remain valid after commencement of the new Act, provided the remittance actually occurred on or before the date mentioned in the form.

Remittance Not Completed Within the Stated Period

Where the remittance was not completed within the relevant period, fresh compliance may be required before processing the payment.

New Remittance After 1 April 2026

For a remittance made on or after 1 April 2026, the new procedural framework applies and the prescribed forms are Form 145 and Form 146.

What If the Expense Relates to FY 2025-26 but Payment Is Made After 1 April 2026?

This is one of the most important transitional issues.

Date of Remittance Determines Procedural Form

The Income Tax Department has specifically considered the example of a liability accrued in February 2026 but remitted in April 2026.

For the procedural reporting requirement, the law applicable on the date of remittance applies.

Therefore, the new Form 145/146 framework applies to the April 2026 remittance.

Taxability May Follow the Earlier Law

The Department also clarifies that taxability of the underlying income follows the Act applicable to the year in which the income accrued.

This distinction can be important for transitional transactions.

Professional Review May Be Necessary

Businesses carrying old-year liabilities into Tax Year 2026-27 should therefore not mechanically apply either the old or new provisions without examining both the underlying taxability and procedural requirements.

How to Determine Which Part of Form 145 Applies

The decision can broadly be approached through a sequence of questions.

Is the Payment to a Non-Resident?

First identify the legal status and tax residence of the recipient.

Is the Payment Taxable in India?

Analyse the nature of income under Indian tax law.

Does a DTAA Apply?

Where India has a DTAA with the recipient’s country, treaty provisions may need to be considered.

What Is the Aggregate Amount?

Determine whether the applicable taxable remittances cross the prescribed threshold.

Is an AO Certificate Available?

If the prescribed Assessing Officer certificate is available, Part B may become relevant.

Is CA Certification Required?

Where the taxable remittance exceeds the threshold and the CA-certification route applies, Form 146 is obtained and Part C of Form 145 is filed.

Why DTAA Analysis Is Important Before Form 146 Certification

A foreign payment may have different tax consequences under domestic law and the applicable tax treaty.

Domestic Tax Law

The transaction must first be characterised correctly under Indian tax law.

Treaty Eligibility

The recipient’s eligibility for treaty benefits should then be evaluated where relevant.

Tax Residency Certificate

Appropriate tax-residency documentation may be required for claiming treaty benefits.

Permanent Establishment

For certain business or service payments, whether the foreign enterprise has a Permanent Establishment in India can materially affect the tax analysis.

Beneficial Treaty Rate

Where the DTAA provides an applicable beneficial treatment and the necessary conditions are satisfied, the treaty position may be considered in determining withholding tax.

Common Payments Requiring Foreign Remittance Review

The requirement for Form 145 and Form 146 should be determined based on the facts of each payment.

Foreign Consultancy Fees

Payments to overseas consultants may require examination of the nature of services and applicable treaty provisions.

Technical Service Fees

Technical services can raise questions relating to domestic tax provisions and the relevant DTAA.

Royalty

Software, technology, intellectual property and licence payments require careful characterisation.

Interest

Interest paid to foreign lenders or group entities can involve withholding tax and treaty considerations.

Commission

Foreign commission arrangements should be examined based on where services are performed, contractual terms and applicable tax provisions.

Import of Services

Payments for overseas services should be reviewed separately from straightforward import of goods.

Reimbursements

Labelling a payment as “reimbursement” does not by itself establish that it is non-taxable.

The underlying expense and contractual arrangement should be examined.

Documents Normally Required for Form 146 Review

Documentation varies according to the transaction.

Invoice

The foreign supplier or recipient’s invoice helps identify the nature and amount of the payment.

Agreement or Contract

The underlying contract can be crucial in determining the legal character of the payment.

Recipient Details

The recipient’s legal name, address, country and tax details should be available.

Tax Residency Certificate

Where treaty benefit is claimed, an appropriate Tax Residency Certificate may be required.

Form 10F or Applicable Treaty Documentation

Applicable tax documentation should be reviewed based on the recipient and treaty claim.

No-PE Declaration

For certain business/service transactions, a No Permanent Establishment declaration may form part of the supporting documentation, depending upon the circumstances.

Remittance Details

Currency, amount, proposed remittance date and bank details should be available.

Previous Remittances

Aggregate payments during the tax year may be relevant for determining the applicable Form 145 part and CA-certification requirement.

Form 145 Filing Process

The Income Tax Department currently provides both online and offline modes for Form 145.

Login to Income Tax Portal

The remitter accesses the e-Filing portal using the appropriate credentials.

Select Form 145

The applicable form and part are selected.

Enter Remittance Details

Details of the remitter, recipient, payment and tax position are furnished.

Link Form 146 Where Required

For Part C, the relevant Chartered Accountant certification must be completed.

Verify and Submit

The form is submitted through the prescribed verification process.

The portal generates a transaction ID and acknowledgement number after successful verification.

Form 146 Certification Process

Where Part C is applicable, CA certification is completed before the corresponding Form 145 filing.

CA Is Added on the Portal

The taxpayer may need to add the Chartered Accountant through the portal.

Form Is Assigned

The applicable Form 146 is assigned to the CA.

CA Reviews Documentation

The CA evaluates the transaction, applicable law and treaty position.

Certificate Is Filed

Form 146 is completed and submitted through the prescribed e-Filing process.

Form 145 Part C Is Completed

After the Form 146 process, the remitter proceeds with the relevant Part C filing.

What Has Not Fundamentally Changed From Form 15CA/15CB?

Although the form numbers changed, the underlying compliance objective remains broadly familiar.

Foreign Remittance Reporting Continues

Applicable payments to non-residents continue to require prescribed information reporting.

Taxability Analysis Continues

Businesses must still determine whether the foreign payment is taxable in India.

Withholding Tax Continues to Matter

TDS compliance remains central to the process.

DTAA Analysis Remains Important

Treaty provisions continue to be relevant where the recipient qualifies for treaty benefits.

CA Certification Continues in Specified Cases

The CA-certification mechanism continues through Form 146.

Important Improvements Under the New Form 145 Framework

The transition is more than simply renumbering the forms.

Clearer Four-Part Structure

The new Form 145 formally continues a structured Part A, B, C and D framework.

Reduced Duplication in Part B Cases

The Income Tax Department states that where Part B is furnished on the basis of an Assessing Officer certificate, Part C is not required under the new framework, removing duplication that existed under the old system.

Structured Purpose of Remittance

The Department’s Form 145 guidance notes that the form seeks the purpose of remittance from a prescribed list, helping standardise reporting.

Online and Offline Filing

Form 145 can currently be filed through online as well as prescribed offline modes.

The Income Tax Department also provides a common offline utility for Forms 145 and 146.

Common Mistakes in Form 145 and Form 146

Foreign-remittance errors can delay bank processing and create tax-compliance issues.

Continuing to Use Form 15CA/15CB for New Remittances

For remittances on or after 1 April 2026, taxpayers should apply the new procedural framework.

Selecting Form Part Only on Amount

Taxability, threshold and certification route should all be considered.

Assuming Every Foreign Payment Is Taxable

The nature and source of income need to be examined.

Assuming Every Foreign Payment Is Non-Taxable

Likewise, an overseas recipient or foreign invoice does not automatically make the payment non-taxable in India.

Ignoring DTAA

The applicable treaty can materially affect the withholding-tax position.

Using Incorrect Nature of Remittance

The description in the form should be consistent with the invoice, agreement and actual transaction.

Filing Without Supporting Documentation

Tax conclusions should be supported by appropriate documents.

Ignoring Aggregate Remittances

The prescribed threshold can involve aggregate remittances during the tax year, not merely one isolated payment.

Role of the Authorised Dealer Bank

Tax compliance and banking documentation often operate together in cross-border payments.

Bank Reviews Remittance Documents

The AD Bank may request documents supporting the nature and purpose of the remittance.

Tax Forms Do Not Replace FEMA Review

Form 145 and Form 146 are income-tax compliance documents.

The foreign payment may separately require consideration under FEMA and RBI regulations.

Additional Documents May Be Requested

Banks may request invoices, agreements, declarations, purpose codes and other supporting information depending upon the transaction.

Form 145 and Form 146 for Companies

Indian companies frequently make overseas payments for business purposes.

Software and Licence Payments

These require careful tax characterisation based on the underlying rights and agreement.

Professional and Consulting Services

The place and nature of services, treaty provisions and PE position may become relevant.

Royalty and Technical Fees

Domestic tax law and treaty definitions should be examined.

Intercompany Payments

Payments to overseas group entities may additionally require transfer pricing and related-party documentation.

Form 145 and Form 146 for Individuals and NRIs

Foreign-remittance reporting is not relevant only to companies.

NRI Repatriation

NRIs may require tax and remittance documentation when repatriating eligible funds from India, depending upon the nature and source of funds.

For broader assistance with Indian taxation of non-residents, see our NRI Taxation Services in India.

Property Sale Proceeds

Repatriation of property sale proceeds may require examination of capital gains, taxes paid and supporting remittance documentation.

Other Personal Remittances

Applicability should be determined according to the nature of the remittance and prescribed exclusions rather than assuming every personal overseas transfer requires Form 145/146.

Form 145 and Form 146 for Businesses Making Overseas Payments

Businesses should build the new forms into their payment-control process.

Review Before Processing Invoice

Tax review should ideally happen before the accounts team releases the overseas payment.

Determine TDS

The applicable withholding-tax position should be established before remittance.

Collect Treaty Documents Early

Where treaty relief is expected, obtain the necessary foreign-recipient documents in advance.

Obtain Form 146 Where Applicable

CA certification should be completed before filing Part C of Form 145.

Coordinate With the Bank

The tax forms and banking documents should be consistent.

Practical Checklist Before Making a Foreign Remittance

A short pre-remittance checklist can prevent delays.

Identify the Recipient

Confirm the recipient’s legal status and country of residence.

Understand the Payment

Review the invoice and agreement.

Determine Taxability

Examine Indian tax provisions applicable to the payment.

Check DTAA

Determine whether treaty relief is available and adequately documented.

Calculate TDS

Compute withholding tax where applicable.

Select Correct Part of Form 145

Determine whether Part A, B, C or D applies.

Obtain Form 146

Where Part C applies, arrange CA certification.

Complete Bank Documentation

Ensure consistency between tax and banking records.

How EzyBiz India Can Assist With Form 145 and Form 146

EzyBiz India Consulting LLP assists individuals and businesses making remittances from India to overseas recipients.

Applicability Review

We review whether Form 145 and/or Form 146 is applicable to the proposed remittance.

Taxability Analysis

We examine the nature of the foreign payment and its Indian tax implications.

DTAA Review

Where applicable, we review the relevant Double Taxation Avoidance Agreement and supporting treaty documentation.

Withholding Tax Calculation

We assist in determining the applicable withholding-tax position.

Form 146 Certification

Where required, our Chartered Accountants can assist with the prescribed CA certification process.

Form 145 Filing Assistance

We assist with preparation and filing of the appropriate part of Form 145.

Bank Coordination

We can assist in addressing tax-related documentation requirements raised during the foreign-remittance process.

For professional assistance, visit our Form 145 and Form 146 Filing Services in India.

Frequently Asked Questions

Has Form 15CA been replaced from 1 April 2026?

Yes. For applicable remittances made on or after 1 April 2026, Form 145 is the corresponding form under the Income Tax Act, 2025 framework.

What is the new Form 15CA called?

The corresponding form under the new framework is Form 145.

What is the new Form 15CB called?

The corresponding Chartered Accountant certificate is Form 146.

When did Form 145 and Form 146 become applicable?

They apply under the new framework for remittances made on or after 1 April 2026.

Is Form 145 the same as Form 15CA?

Form 145 is the corresponding information form under the Income Tax Act, 2025 framework. Although its role broadly corresponds to old Form 15CA, taxpayers should use the new prescribed form and current rules for applicable remittances.

Is Form 146 the same as Form 15CB?

Form 146 is the corresponding Chartered Accountant certificate under the new framework and replaces old Form 15CB for applicable remittances.

Is Form 146 mandatory for every foreign remittance?

No. Applicability depends upon factors including taxability, amount and the applicable certification route.

What is the ₹5 lakh limit for Form 146?

For a taxable remittance exceeding the prescribed ₹5 lakh threshold during the tax year, Form 146 is relevant where the CA-certification route for Part C of Form 145 applies.

How many parts are there in Form 145?

Form 145 contains four parts — A, B, C and D.

Which part of Form 145 requires Form 146?

Form 146 is relevant for Part C where the prescribed conditions are satisfied.

Can old Form 15CA/15CB remain valid after 1 April 2026?

Forms filed for qualifying remittances before 31 March 2026 can remain valid after commencement of the new Act provided the actual remittance occurred on or before the date stated in the forms.

What happens if an invoice relates to March 2026 but payment is made in April 2026?

The Income Tax Department has clarified that the procedural reporting requirement follows the law in force on the date of remittance. Therefore, the new procedural framework applies to an April 2026 remittance, while taxability of the underlying income follows the law applicable to the year of accrual.

Can Form 145 be filed online?

Yes. The Income Tax Department currently provides online and prescribed offline filing options.

Who issues Form 146?

Form 146 is the prescribed certificate of an accountant for applicable payments to non-residents or foreign companies.

Should I obtain Form 146 before filing Form 145 Part C?

Yes. The Income Tax portal identifies CA filing of Form 146 as a prerequisite for Part C.

Does Form 145/146 compliance also cover FEMA?

No. These are income-tax reporting/certification requirements. FEMA and authorised dealer bank requirements may need to be considered separately.

Related Services

• Form 145 & Form 146 Filing Services in India
• Form 15CA & Form 15CB / Foreign Remittance Services
• Direct Tax Advisory Services in India
• NRI Taxation Services in India
• Income Tax Assessment & Litigation Services

Official References

For current filing requirements, taxpayers should refer to the Income Tax Department’s Form 145 guidance and the Income Tax Department’s Forms and transition guidance. The Department also provides the official Form 145 and Form 146 offline utility.

Prepared By:
EzyBiz India Consulting LLP
Chartered Accountants & Tax Advisors

Last Updated:
September 2026

Disclaimer:
This article is intended for general informational purposes only and should not be considered tax, legal, FEMA, RBI or other professional advice. Applicability of Form 145, Form 146, withholding tax and DTAA provisions depends upon the nature of the remittance, taxability of the payment, amount, recipient status, applicable treaty, supporting documents and facts of each transaction. The applicable law, rules, forms and portal procedures may change. Professional advice should therefore be obtained before making a foreign remittance or determining the applicable withholding-tax and reporting requirements.