Form 145 and Form 146 vs Form 15CA and Form 15CB – Key Changes From April 2026

Form 145 and Form 146 vs Form 15CA and Form 15CB is an important comparison for Indian businesses, individuals and NRIs making payments to non-residents and foreign companies.

Important update – October 2026: With effect from 1 April 2026, Form 145 replaces the earlier Form 15CA and Form 146 replaces Form 15CB under the Income-tax Act, 2025 and Income-tax Rules, 2026. The new forms apply to relevant remittances under the current reporting framework.

Although the basic obligation to examine taxability, withholding tax and foreign-remittance reporting continues, the new framework introduces updated statutory references, filing formats, Chartered Accountant certification procedures and certain compliance improvements.

This guide explains the differences between the old and new forms, the Rs. 5 lakh threshold, Form 145 Parts A, B, C and D, Form 146 certification, reporting exemptions, transitional payments and practical filing requirements.

EzyBiz India Consulting LLP assists Indian companies, foreign subsidiaries, importers, entrepreneurs and individuals with Form 145 filing, Form 146 CA certification, DTAA review and foreign-remittance tax compliance.

For assistance, call +91 98992 17778 or email anil@ezybizindia.in.

Visit our Form 145 and Form 146 Filing Services in India page for professional support.

What Changed From 1 April 2026?

Form 15CA Was Replaced by Form 145

Under the earlier Income-tax Act, 1961, Form 15CA was used to furnish prescribed information relating to specified payments made to non-residents and foreign companies.

Under the Income-tax Act, 2025, the corresponding remitter declaration is Form 145. It continues to capture information relating to the payment, foreign recipient, taxability and applicable withholding tax.

Form 15CB Was Replaced by Form 146

Form 15CB was the earlier Accountant’s certificate supporting specified foreign-remittance reporting requirements.

Form 146 is its successor under the Income-tax Act, 2025. It is prepared by an eligible Chartered Accountant where the prescribed certification conditions apply.

New Forms Apply From the Remittance Date

For relevant remittances made on or after 1 April 2026, the prescribed procedural reporting forms are Forms 145 and 146.

Remittances completed under the earlier framework before that date continue to be assessed according to the applicable historical reporting requirements.

The Income Tax Department has clarified the transition in its official guidance available at Income Tax Forms – Transition FAQs.

Old and New Forms – Detailed Comparison Table

Comparison of Form Numbers and Legal Provisions

Particulars	Earlier framework	From 1 April 2026
Applicable legislation	Income-tax Act, 1961	Income-tax Act, 2025
Reporting provision	Section 195(6)	Section 397(3)(d)
Relevant reporting rule	Rule 37BB	Rule 220
Remitter declaration	Form 15CA	Form 145
Accountant’s certificate	Form 15CB	Form 146
Taxable payment threshold	Rs. 5 lakh aggregate framework	Rs. 5 lakh aggregate framework
Remitter declaration parts	Part A, B, C and D	Part A, B, C and D
CA certification route	Form 15CB followed by Form 15CA Part C	Form 146 followed by Form 145 Part C
Prescribed Assessing Officer route	Form 15CA Part B	Form 145 Part B
Form 146-specific UDIN integration	Not applicable as Form 146	Prescribed UDIN validation

What Has Remained Substantially Similar?

The requirement to assess the taxability of applicable non-resident payments continues. Taxpayers must still consider the character of income, applicable domestic income-tax provisions, DTAA benefits and withholding-tax obligations.

The Rs. 5 lakh threshold continues to determine important reporting distinctions for taxable remittances.

What Has Changed Operationally?

The new forms operate under revised legislation and updated electronic filing facilities. Form 146 includes UDIN validation, and the Form 145 Part B route expressly removes duplicate Part C filing where the prescribed Assessing Officer certificate or order is available.

The new reporting framework also provides the prescribed Form 145 remittance-purpose information and current online and offline filing procedures.

Form 145 vs Form 15CA – Main Differences

Difference in Statutory Authority

Form 15CA was associated with Section 195(6) of the Income-tax Act, 1961 and Rule 37BB of the Income-tax Rules, 1962.

Form 145 is prescribed under the Income-tax Act, 2025 and Rule 220 of the Income-tax Rules, 2026.

Who Files Form 145 and Who Filed Form 15CA?

Both forms relate to information furnished by the person responsible for making a relevant payment to a non-resident, not being a company, or to a foreign company.

The remitter is responsible for examining the reporting requirements and furnishing the applicable declaration.

Four-Part Reporting Structure Continues

Both forms use a four-part structure, although the current filing requirements are governed by Rule 220.

Form 145 Part A covers relevant taxable payments within the prescribed threshold, while Parts B and C address applicable taxable payments exceeding the threshold. Part D applies to non-chargeable payments not covered by a prescribed reporting exclusion.

For detailed applicability, read our Form 145 Filing Guide covering Parts A, B, C and D.

Form 146 vs Form 15CB – Main Differences

Accountant’s Certificate Under the New Framework

Form 146 replaces Form 15CB as the prescribed Accountant’s certificate for relevant taxable payments to non-residents and foreign companies.

The Chartered Accountant examines the payment’s taxability under Indian law, relevant DTAA provisions, applicable withholding tax and supporting documents.

Digital Signature and UDIN Validation

Form 146 is electronically submitted using the Chartered Accountant’s registered Digital Signature Certificate.

The new framework also provides for UDIN validation, improving the verification and authenticity of the certificate.

Relationship With Form 145 Part C

Where the prescribed Form 145 Part C route applies, the Chartered Accountant files Form 146 first. The remitter subsequently uses its acknowledgement details to complete Form 145 Part C.

For further information, read our Form 146 CA Certificate guide covering documents, fees and filing.

Form 145 Part A, B, C and D – Current Applicability

Part A for Taxable Payments Up to Rs. 5 Lakh

Form 145 Part A generally applies where the payment is chargeable to income tax in India and the payment or aggregate of relevant payments does not exceed Rs. 5 lakh during the tax year.

Form 146 certification is not required for the prescribed Part A reporting route.

Part B and Part C for Payments Above Rs. 5 Lakh

Part B generally applies where the taxable payment or aggregate exceeds Rs. 5 lakh and the prescribed Assessing Officer certificate or order under Section 395(1) or 395(2) is available.

Part C generally applies where the taxable payment or aggregate exceeds Rs. 5 lakh and the remitter obtains an Accountant’s certificate in Form 146.

Where Part B is properly furnished, Part C is not required for the same reporting obligation.

Part D for Non-Chargeable Payments

Form 145 Part D generally applies to payments that are not chargeable to income tax in India but are not excluded from reporting under Rule 220(3).

The absence of Indian tax liability does not automatically mean that no remittance declaration is required.

Form 145 part	Applicable situation	Form 146 needed?
Part A	Taxable payment or aggregate up to Rs. 5 lakh	No
Part B	Taxable payment above threshold with prescribed AO certificate or order	No
Part C	Taxable payment above threshold supported by Accountant’s certificate	Yes
Part D	Non-chargeable payment not covered by Rule 220(3) exclusion	No

Important Improvements Under the New Reporting Framework

Reduced Duplication in Assessing Officer Certificate Cases

One important clarification under Rule 220 is that where Form 145 Part B is furnished using the prescribed Assessing Officer certificate or order, Part C is not also required.

This can reduce duplicated certification and reporting for applicable remittances.

Structured Remittance Purpose Information

Form 145 requires prescribed particulars of the remittance, including the relevant payment purpose.

Businesses should select the appropriate purpose based on the underlying invoice, agreement and actual transaction.

Updated Online and Offline Filing Facilities

Form 145 and Form 146 can be filed through the prescribed electronic filing procedures. An official common offline utility is also available for preparing the new forms.

Refer to the Income Tax Department’s Forms 145 and 146 utility page.

Does the Rs. 5 Lakh Threshold Change Under Forms 145 and 146?

The Threshold Remains Relevant

The Income-tax Rules, 2026 retain the Rs. 5 lakh framework for determining the applicable reporting route for taxable remittances.

Where the relevant amount or aggregate does not exceed Rs. 5 lakh during the tax year, Part A generally applies.

The Threshold Is Not a General Tax Exemption

The Rs. 5 lakh threshold does not exempt an otherwise taxable foreign payment from income tax or withholding-tax compliance.

The chargeability of the underlying payment must be examined separately from the reporting threshold.

Aggregate Payments Must Be Considered

The threshold is based on the payment or aggregate of relevant payments during the tax year, rather than automatically applying to each invoice independently.

Businesses making recurring overseas payments should maintain appropriate remittance records when determining the correct filing part.

What Happens to Old Forms Filed Before April 2026?

Validity of Forms 15CA and 15CB Filed Earlier

Forms 15CA and 15CB filed for remittances completed under the earlier framework remain relevant historical compliance records.

The Income Tax Department has confirmed the continued validity of eligible earlier forms where the remittance was actually made within the relevant period stated in the filing.

When Fresh Forms May Be Required

If an earlier Form 15CA or Form 15CB was filed but the remittance was not completed within the applicable period, fresh reporting may be necessary before processing the later payment.

For a remittance taking place on or after 1 April 2026, the applicable procedural form is determined under the new framework.

Historical Records Should Be Preserved

Businesses should preserve historical Forms 15CA and 15CB, acknowledgements, certificates, invoices, tax computations and supporting bank documents.

These records may be relevant for explaining earlier remittances, tax deductions and compliance decisions.

Invoice Before April 2026 but Payment After April 2026

Example of a February 2026 Invoice Paid in April 2026

Assume an Indian company receives an overseas service invoice in February 2026 but makes the remittance in April 2026.

The procedural reporting requirements for the April 2026 remittance generally follow the Income-tax Act, 2025 and the corresponding Forms 145 and 146.

Taxability May Follow the Earlier Accrual Period

The Income Tax Department’s transition guidance explains that the taxability of the underlying income is governed by the law applicable to its accrual period.

Accordingly, determining the substantive income-tax position may require examining the earlier Income-tax Act, 1961 even when the remittance reporting uses the new forms.

Review Withholding and Documentation Separately

The appropriate withholding treatment, tax rates, treaty provisions and timing of deduction must be reviewed with reference to the relevant transaction and transitional provisions.

Businesses should not assume that the new reporting form alone determines the substantive tax liability.

Differences in CA Certification and Assessing Officer Routes

Earlier Form 15CB and Form 15CA Part C

Under the earlier reporting framework, Form 15CB was certified by a Chartered Accountant and used for the relevant Part C filing of Form 15CA.

Other prescribed reporting routes applied where an Assessing Officer certificate or order existed.

Current Form 146 and Form 145 Part C

Under the current framework, Form 146 is prepared by an eligible Chartered Accountant and used for the relevant Part C filing of Form 145.

The CA is assigned through the Income Tax e-Filing portal, certifies the relevant payment information and completes the prescribed verification requirements.

Assessing Officer Certificate and Part B

Where the prescribed certificate or order under Section 395(1) or 395(2) supports Form 145 Part B, Form 146 is not separately required for the same reporting obligation.

This distinction is important for avoiding unnecessary certification costs.

Changes in Foreign Remittance Exemptions

Earlier Exclusions Under Rule 37BB

The earlier Rule 37BB framework provided reporting exclusions for specified non-chargeable remittances, including certain payments covered by prescribed RBI purpose codes.

Taxpayers needed to examine the actual transaction and relevant statutory conditions before claiming an exclusion.

Current Exclusions Under Rule 220(3)

Rule 220(3) contains the current reporting exclusions for specified payments that are not chargeable to income tax in India.

These include qualifying categories specified in the rule, subject to the applicable conditions and remittance-purpose classifications.

Refer to Rule 220 of the Income-tax Rules, 2026 for the complete statutory provisions.

Import Payments and RBI Purpose Codes

Specified non-taxable import payments may qualify for reporting exclusions under Rule 220(3), including relevant advance import payments and settlement of import invoices.

Where a purchase agreement includes taxable royalty, technical services or other income components, those amounts require separate examination.

Read our article on Form 15CB and Form 146 applicability for foreign purchase payments.

Foreign Payments Requiring Taxability Review

Technical Services and Foreign Consultancy Fees

Payments to overseas consultants, technical service providers, engineering firms and professional advisers may raise questions under Indian income-tax law and applicable DTAAs.

Classification depends on the actual nature of services and relevant statutory or treaty provisions.

Software, Royalty and Intellectual Property

Payments involving software licences, intellectual property, technology rights and technical know-how may require royalty or other income classification analysis.

Not every software payment is automatically royalty, and the rights granted under the agreement should be examined.

Interest, Dividends and Intercompany Charges

Foreign remittances involving interest, dividends, management charges, shared service fees and other related-party transactions may involve withholding-tax and DTAA requirements.

Separate transfer pricing or FEMA obligations may also apply where relevant.

Documents Required Under the New Reporting Framework

Documents of the Indian Remitter

• PAN and TAN, where applicable.
• Name, address and legal status.
• Authorised signatory details.
• Bank and authorised dealer details.
• Relevant prior remittances during the tax year.
• Income Tax e-Filing portal authorisation.

Documents of the Foreign Recipient

• Foreign recipient’s legal name and address.
• Country of tax residence.
• Foreign tax identification particulars, where available.
• Tax Residency Certificate, where relevant.
• Form 41 or other applicable treaty information.
• Relevant permanent establishment and beneficial ownership declarations.

Agreement, Invoice and Tax Documents

• Commercial invoice or payment request.
• Service, licence, purchase or other relevant agreement.
• Nature and purpose of payment.
• Amount, currency and proposed payment date.
• Relevant domestic income-tax and DTAA computations.
• Withholding-tax calculation, where applicable.
• Prescribed Assessing Officer certificate or order, where applicable.
• Form 146 acknowledgement for the Part C route.

The exact documentary requirements depend on the transaction and prescribed filing part.

Filing Process – Form 145 and Form 146 Compared With Earlier Forms

Earlier Form 15CB and Form 15CA Filing Sequence

Under the earlier CA-certification route, the taxpayer assigned Form 15CB to the Chartered Accountant.

The CA completed and submitted Form 15CB, following which the remitter used the acknowledgement to furnish Form 15CA Part C.

Current Form 146 and Form 145 Filing Sequence

Under the current Part C route, the taxpayer first assigns Form 146 to the Chartered Accountant.

The CA completes the certification, electronically verifies it through the prescribed DSC process and validates the applicable UDIN.

The remitter then uses the Form 146 acknowledgement to prepare and submit Form 145 Part C.

Online and Offline Filing Options

The current forms can be prepared through the Income Tax e-Filing portal or the prescribed offline utility.

Successful electronic verification and submission are necessary to complete the applicable filing requirement.

For detailed procedural instructions, see our Step-by-Step Guide to Form 15CA/15CB and New Forms 145/146.

Practical Examples of Old and New Form Applicability

Taxable Foreign Payment of Rs. 3 Lakh

Assume an Indian company makes a taxable payment of Rs. 3 lakh to an overseas consultant and the relevant aggregate during the tax year does not exceed Rs. 5 lakh.

Under the earlier applicable framework, Form 15CA Part A generally applied. Under the current framework, Form 145 Part A generally applies.

Taxable Foreign Payment of Rs. 12 Lakh

Assume an Indian company proposes a taxable payment of Rs. 12 lakh to an overseas service provider without obtaining the prescribed Assessing Officer certificate.

Under the earlier applicable framework, Form 15CB followed by Form 15CA Part C generally applied. Under the current framework, Form 146 followed by Form 145 Part C generally applies.

Non-Taxable Import of Goods

Assume an Indian importer purchases ordinary goods from a foreign supplier, and the payment is not chargeable to Indian income tax.

The importer should examine the prescribed reporting exclusions under the applicable old or new rule. Where a qualifying exclusion applies, the relevant remittance declaration and CA certificate would generally not be required.

Frequently Asked Questions on the New Forms

Are Forms 15CA and 15CB Still Used After April 2026?

For relevant remittances made on or after 1 April 2026, the prescribed forms are Form 145 and Form 146.

Historical Forms 15CA and 15CB remain relevant for eligible earlier remittances and supporting compliance records.

Is Form 146 Required for Every Payment Above Rs. 5 Lakh?

No. Form 146 is required for the applicable Form 145 Part C certification route. The payment must be examined for Indian taxability, the prescribed threshold and availability of an Assessing Officer certificate or order.

Does Filing Form 145 or Form 146 Replace FEMA Compliance?

No. Income-tax remittance reporting and Chartered Accountant certification do not replace applicable FEMA, RBI, Customs or authorised dealer bank requirements.

Businesses may need to provide separate banking and regulatory documents.

For additional historical questions, see our FAQs on Form 15CA and Form 15CB.

Form 145 and Form 146 Compliance Services by EzyBiz India

Professional Review of Old and New Requirements

EzyBiz India Consulting LLP assists companies and individuals with understanding the applicable form requirements and determining the correct reporting procedure for relevant foreign payments.

Our services include reviewing taxability, payment documentation, statutory provisions and relevant treaty benefits.

Form 145 Filing and Form 146 CA Certification

Our tax and regulatory services include:

• Form 145 applicability and Part A, B, C or D assessment.
• Form 146 Chartered Accountant certification.
• Foreign-remittance taxability review.
• Withholding-tax calculations.
• DTAA and supporting treaty documentation.
• Review of prescribed reporting exclusions.
• Electronic filing and acknowledgement assistance.
• Coordination of related bank and FEMA documentation.

Contact Our International Tax Team

For assistance with a foreign payment, share the nature of remittance, payment amount, recipient country, invoice, agreement and proposed payment date.

Our team can review the requirements and provide a transaction-specific professional quotation.

Mobile: +91 98992 17778

Email: anil@ezybizindia.in

Contact EzyBiz India Consulting LLP

306, 3rd Floor, Vishwa Sadan Building, District Centre, Janakpuri, New Delhi – 110058, India.

Mobile: +91 98992 17778

Email: anil@ezybizindia.in

WhatsApp: Chat with our tax team

Related Services and Supporting Guides

• Form 145 and Form 146 Filing Services in India
• Form 145 Filing – Parts A, B, C, D and Exemptions
• Form 146 CA Certificate – Filing, Documents and Fees
• Form 15CA and Form 15CB – Earlier Framework
• FAQs on Form 15CA and Form 15CB
• Step-by-Step Filing Guide for Forms 15CA, 15CB, 145 and 146
• Form 15CB and Form 146 for Foreign Purchase Payments

Official Regulatory References

• Income Tax Department – Transition and New Forms Guidance
• Income Tax Department – Rule 220
• Income Tax Department – Form 145 User Manual
• Income Tax Department – Form 146 User Manual
• Official Form 145 and Form 146 Filing Utilities
• Income Tax e-Filing Portal

Reviewed By: CA Anil Agrawal, Founder, EzyBiz India Consulting LLP.

Last Updated: October 2026

Disclaimer: This article provides general information comparing earlier Forms 15CA and 15CB under the Income-tax Act, 1961 with Forms 145 and 146 under the Income-tax Act, 2025 and Income-tax Rules, 2026. The applicable reporting obligations, withholding-tax treatment and certification requirements depend on the remittance date, nature and chargeability of income, statutory provisions, applicable DTAA, supporting documentation and prescribed reporting exclusions. Taxpayers should obtain transaction-specific professional advice before making foreign payments or claiming treaty relief. This article does not constitute a formal tax opinion or Chartered Accountant certificate. Income-tax reporting does not replace applicable FEMA, RBI or authorised dealer requirements. Laws, rules and portal procedures may change.