Form 146 CA Certificate in India – Applicability, Documents, Fees and Filing

The Form 146 CA Certificate is an Accountant’s certificate prescribed for certain taxable payments made to non-residents or foreign companies. From 1 April 2026, Form 146 replaces the earlier Form 15CB under the Income-tax Act, 2025 and Income-tax Rules, 2026.

Before making an applicable foreign remittance, an Indian business or individual must examine the nature of payment, Indian income-tax liability, applicable withholding tax, Double Taxation Avoidance Agreement (DTAA) benefits and prescribed reporting requirements.

Where Chartered Accountant certification is required, Form 146 is prepared and electronically submitted by an eligible Chartered Accountant before the remitter completes Part C of Form 145.

EzyBiz India Consulting LLP provides professional assistance with Form 146 certification, foreign-remittance tax review, DTAA advisory, withholding-tax computations and related compliance for Indian companies, overseas subsidiaries, importers, entrepreneurs and individuals.

For Form 146 assistance, call +91 98992 17778 or email anil@ezybizindia.in.

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

What Is Form 146 CA Certificate?

Meaning and Purpose of Form 146

Form 146 is an Accountant’s certificate for prescribed payments to a non-resident, not being a company, or to a foreign company. It supports the reporting requirements applicable to foreign remittances that are chargeable to income tax in India.

The certificate records the Chartered Accountant’s examination of the transaction, including the relevant income-tax provisions, DTAA treatment and withholding-tax particulars.

Form 146 Replaces Earlier Form 15CB

Form 146 is the successor to Form 15CB under the new income-tax framework applicable from 1 April 2026. Similarly, Form 145 replaces the earlier Form 15CA.

The earlier forms remain relevant when examining historical remittances, previous tax periods and older documentation. Read our Form 145 and 146 vs Form 15CA and 15CB comparison for details.

Who Can Issue Form 146?

An eligible Chartered Accountant registered on the Income Tax e-Filing portal can prepare and electronically certify Form 146 after the taxpayer assigns the form to that CA.

The Chartered Accountant must have a valid Digital Signature Certificate registered on the portal and comply with the applicable electronic verification and UDIN requirements.

Legal Provisions Governing Form 146

Income-tax Act, 2025

The Income-tax Act, 2025 governs the current foreign-remittance withholding and reporting framework. Relevant provisions include section 393 concerning tax deduction on payments to non-residents, section 395 concerning applications for determination or certificates, and section 397 concerning related withholding compliance and information requirements.

The applicable statutory provisions must be interpreted alongside the nature of income, applicable charging provisions and relevant treaty provisions.

Rule 220 of Income-tax Rules, 2026

Rule 220 prescribes the reporting requirements for specified payments to non-residents and foreign companies, including the conditions relating to Form 145 and Form 146.

Form 146 is prescribed under Rule 220(1)(c). The remitter should determine whether the payment satisfies the conditions for Chartered Accountant certification before assigning the form.

The statutory format may be examined in the notified Income-tax Rules, 2026.

Form 145 and Form 146 – Different Responsibilities

Form 145 is the remitter’s information declaration, while Form 146 is the Accountant’s certificate supporting Part C of Form 145.

The Chartered Accountant first certifies the relevant transaction in Form 146. The remitter then uses the Form 146 acknowledgement details to complete Form 145 Part C before the foreign remittance.

Refer to the official Form 145 User Manual for the prescribed process.

When Is Form 146 Mandatory?

Taxable Remittance Exceeding Rs. 5 Lakh

Form 146 is generally required where the payment to a non-resident or foreign company is chargeable to income tax in India, the payment or aggregate of relevant payments exceeds Rs. 5 lakh during the tax year, and the remitter is required to file Form 145 Part C.

The threshold must be considered in relation to the prescribed aggregate during the tax year and not merely in isolation for each invoice.

Requirement Where No Assessing Officer Certificate Exists

Where the taxable remittance exceeds the prescribed threshold and the remitter has not obtained the relevant certificate from the Assessing Officer under section 395(1) or section 395(2), the Chartered Accountant certification route generally applies.

In such cases, Form 146 supports the information furnished in Form 145 Part C.

Situations Where Form 146 Is Not Required

Form 146 is not required merely because funds are being transferred abroad. It is generally unnecessary where the payment is not chargeable to income tax in India, the taxable remittance falls within the Part A threshold, or the remitter is eligible to file Part B on the basis of the prescribed Assessing Officer certificate.

Where the payment is not chargeable to tax, Form 145 Part D may still be required unless the transaction is excluded under Rule 220(3).

Form 146 Applicability – Practical Decision Table

The following table summarises the principal reporting routes under the current framework.

Nature of remittance	Form 145 requirement	Form 146 requirement
Taxable remittance not exceeding Rs. 5 lakh in the tax year	Part A	Not required
Taxable remittance exceeding Rs. 5 lakh with prescribed Assessing Officer certificate	Part B	Not required
Taxable remittance exceeding Rs. 5 lakh without prescribed Assessing Officer certificate	Part C, supported by Form 146	Required
Non-taxable remittance not covered by a reporting exclusion	Part D	Not required
Remittance covered by Rule 220(3) reporting exclusion	Generally not required under the applicable exclusion	Not required under that reporting route

Important: This table is a general decision aid. The correct treatment should be confirmed after examining transaction-specific taxability, the applicable statutory conditions and relevant supporting documents.

Documents Required for Form 146 CA Certificate

Documents and Details of the Indian Remitter

The following details are ordinarily required:

• Name and legal status of the remitter.
• PAN and TAN, where applicable.
• Registered address and contact particulars.
• Authorised signatory details.
• Income Tax e-Filing portal access and CA assignment.
• Bank and authorised dealer details.
• Details of relevant earlier remittances during the tax year.

Documents and Details of the Foreign Recipient

• Legal name and address of the foreign recipient.
• Country of residence and applicable tax status.
• Foreign Tax Identification Number or PAN, where available.
• Tax Residency Certificate where treaty relief is claimed.
• Form 41, the successor to the earlier Form 10F, where applicable.
• Relevant beneficial ownership and permanent establishment declarations.
• Any additional documents necessary to establish treaty eligibility.

Invoice, Agreement and Remittance Documents

• Commercial invoice or payment request.
• Service agreement, consultancy agreement or other relevant contract.
• Purchase order or engagement letter, where applicable.
• Nature and purpose of the proposed remittance.
• Amount and currency of the payment.
• Proposed remittance date.
• Applicable withholding-tax computation.
• Relevant supporting correspondence and declarations.
• Previous tax certificates or Assessing Officer orders, where relevant.

The exact documentary requirements differ for royalty, professional services, consultancy fees, interest, dividends, software payments and other types of transactions.

Taxability and DTAA Review Before Certification

Determining Whether the Payment Is Taxable in India

Before issuing Form 146, the Chartered Accountant must examine whether the proposed payment is chargeable to income tax in India.

The assessment may include the recipient’s residential status, source and nature of income, contractual arrangements, relevant charging provisions and applicable judicial principles.

Making a payment to a foreign party does not automatically establish that Indian withholding tax applies.

Applying Double Taxation Avoidance Agreements

Where India has a DTAA with the foreign recipient’s country of tax residence, the treaty may provide a more beneficial rate or determine whether particular income is taxable in India.

The relevant treaty article must be examined before applying treaty benefits. Read the applicable agreement through the Income Tax Department’s official website.

Tax Residency Certificate and Form 41

A Tax Residency Certificate is an important supporting document where treaty benefits are claimed. Additional prescribed information may be required in Form 41 under the new framework.

The Chartered Accountant should examine whether the prescribed documentation and relevant treaty conditions have been satisfied before taking a beneficial treaty position.

TDS on Foreign Remittances and Form 146

Withholding Tax on Non-Resident Payments

Payments to non-residents may attract withholding tax where the amount is chargeable to income tax in India under the applicable provisions.

The nature of the income and the relevant tax provisions determine whether tax must be deducted and at what rate.

Determining the Applicable TDS Rate

The applicable rate may differ for royalty, fees for technical services, dividends, interest, professional services and other income categories.

The correct rate should be determined after considering domestic law, applicable treaty provisions, surcharge and cess where relevant, and the eligibility of the foreign recipient for treaty relief.

No universal TDS rate applies to every foreign remittance.

Grossing Up and Tax-Borne Payments

Where the Indian payer has contractually agreed to bear the foreign recipient’s tax liability, the applicable grossing-up provisions may affect the amount on which withholding tax is calculated.

The underlying agreement should be reviewed before arriving at the final tax computation.

Common Foreign Payments Requiring Form 146 Review

Royalty and Software Payments

Cross-border payments involving software licences, intellectual property, technical know-how and other rights may require examination under domestic royalty provisions and the applicable treaty.

The precise rights granted and commercial substance of the arrangement are relevant to the tax determination.

Foreign Consultancy and Technical Services

Payments for consultancy, management support, engineering, technical services and professional services may require examination under the relevant income-tax provisions and treaty articles.

Taxability depends on the nature of services, relevant source rules, treaty provisions and other material circumstances.

Dividend, Interest and Intercompany Charges

Payments of dividends, interest, management fees, shared service charges and other intragroup amounts may involve withholding-tax, treaty and transfer pricing considerations.

Where relevant, the certification review should be coordinated with the company’s international tax and intercompany documentation.

Form 146 for Import of Goods and Services

Payments for Import of Goods

An ordinary payment for goods imported from a foreign supplier does not automatically become taxable in India merely because the supplier is located overseas.

However, a transaction may require additional examination if the arrangement includes technical services, royalties, licence fees or other potentially taxable components.

For further background, read our article on Form 15CB requirements for foreign purchase payments, while applying the new Form 146 framework to current remittances.

Payments for Import of Services

Foreign consultancy, software implementation, engineering, advertising and other service payments should be examined according to their actual nature and the applicable income-tax and treaty provisions.

GST and FEMA requirements, where applicable, are separate from the prescribed income-tax certification and reporting obligations.

Step-by-Step Form 146 Filing Process

Assign Form 146 to the Chartered Accountant

The remitter logs into the Income Tax e-Filing portal and adds or authorises the relevant Chartered Accountant using the prescribed CA assignment facility.

The taxpayer assigns Form 146 to the CA through the applicable portal workflow.

Review the Documents and Taxability

The Chartered Accountant examines the agreement, invoice, payment particulars, recipient documents, relevant tax provisions, DTAA treatment and proposed withholding-tax computation.

Any missing documents or unclear tax positions should be resolved before certification.

Prepare Form 146 on the Income Tax Portal

The Chartered Accountant accesses the assigned Form 146 through the e-Filing portal, completes the prescribed reporting fields and reviews the entered details.

The form may be prepared using the permitted online filing facility or prescribed offline utility, as applicable.

Submit Form 146 and Complete Form 145 Part C

The Chartered Accountant electronically verifies and submits Form 146 using the registered Digital Signature Certificate.

After successful filing, the Form 146 acknowledgement details are used by the remitter to complete Form 145 Part C before making the applicable foreign payment.

For detailed portal instructions, refer to the official Form 146 User Manual.

Information Reported in Form 146

Remitter, Recipient and Transaction Particulars

Form 146 collects details relating to the Indian remitter, foreign recipient and proposed remittance, including identification particulars, payment amount, purpose and other prescribed information.

Income-Tax, DTAA and Verification Details

The certificate also records taxability under domestic income-tax provisions, treatment under the applicable DTAA, withholding-tax particulars and verification by the Chartered Accountant.

The official filing manual identifies seven reporting panels:

1. Particulars of the remitter.
2. Particulars of the foreign recipient.
3. Particulars of the remittance.
4. Taxability under the Income-tax Act without DTAA.
5. Taxability under the applicable DTAA.
6. Details of tax deducted at source.
7. Verification by the Chartered Accountant.

Form 146 CA Certificate Fees in India

Factors Affecting Form 146 Certification Fees

Professional fees for Form 146 certification depend on the nature of payment, transaction value, completeness of documentation, complexity of taxability analysis, applicable DTAA provisions and extent of withholding-tax review.

There is no single professional fee that is appropriate for every transaction.

Simple and Complex Foreign Remittance Cases

A straightforward payment with complete documents and a clearly established tax position may involve less professional work than a complex royalty arrangement, intercompany payment, software licensing transaction or cross-border service agreement.

Specialised tax opinions and extensive documentation reviews may require separate professional engagement.

Request a Form 146 Certification Fee Quote

EzyBiz India Consulting LLP provides transaction-specific quotations after examining the proposed remittance.

Share the payment amount, nature of transaction, recipient country and proposed payment date with our team.

Mobile: +91 98992 17778

Email: anil@ezybizindia.in

Form 146 Filing Timeline, DSC and UDIN

When Should Form 146 Be Completed?

Form 146 is associated with the relevant remittance rather than an annual return-filing deadline. It should be completed before the payment so that the remitter can file Form 145 Part C in advance.

Businesses should begin the documentation and certification process sufficiently early to accommodate tax review and banking formalities.

Digital Signature and UDIN Verification

The Chartered Accountant must electronically submit Form 146 using the registered Digital Signature Certificate.

The current framework also provides UDIN-based verification. The CA should complete the applicable UDIN validation and maintain the certificate acknowledgement and supporting professional records.

Common Mistakes in Form 146 Certification

Incorrect Classification of Foreign Payments

Incorrectly treating a royalty payment as ordinary business income, or failing to identify a taxable service component, may result in an incorrect withholding-tax position.

Incomplete DTAA Documentation

Claiming treaty benefits without examining the foreign recipient’s tax residency, supporting declarations and applicable treaty conditions can create tax and compliance exposure.

Incorrect Form 145 Part or Withholding Computation

Using the wrong Form 145 part, overlooking an applicable Assessing Officer certificate, ignoring aggregate payments or applying an incorrect TDS rate can lead to unnecessary certification or inaccurate reporting.

Appropriate taxability review should be completed before selecting the reporting route.

Practical Examples of Form 146 Applicability

Foreign Technical Consultancy Payment

An Indian company proposes to pay Rs. 12 lakh to an overseas technical consultant.

The company should first determine the payment’s taxability under Indian income-tax law and the applicable DTAA. If the payment is chargeable to tax, exceeds the prescribed threshold and the relevant Assessing Officer certificate has not been obtained, Form 146 would generally be required for Form 145 Part C.

Purchase of Goods from an Overseas Supplier

An Indian importer purchases trading goods from a foreign supplier for Rs. 15 lakh.

The payment must be examined according to its actual nature. If the consideration is not chargeable to income tax in India, a Form 146 certificate is generally unnecessary. The correct Form 145 reporting position and any Rule 220(3) exclusion should still be assessed.

Payment Covered by an Assessing Officer Certificate

An Indian company proposes a taxable foreign remittance exceeding Rs. 5 lakh and has obtained the prescribed Assessing Officer certificate.

Where Form 145 Part B applies on the basis of that certificate, a separate Form 146 certificate is not required.

Frequently Asked Questions on Form 146

Is Form 146 the Same as Earlier Form 15CB?

Form 146 is the successor to Form 15CB under the Income-tax Act, 2025 and Income-tax Rules, 2026. It applies to relevant remittances under the new framework from 1 April 2026.

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

No. The remittance must be examined for Indian taxability, the applicable reporting threshold and the prescribed compliance route. Form 146 is not universally required for payments exceeding Rs. 5 lakh.

Can Form 146 Be Filed Without a Chartered Accountant?

No. Form 146 is an Accountant’s certificate requiring certification by an eligible Chartered Accountant authorised through the Income Tax e-Filing portal.

Is Form 146 Required When an Assessing Officer Certificate Is Available?

No separate Form 146 certificate is required where the applicable Assessing Officer certificate supports filing Form 145 Part B in accordance with the prescribed conditions.

Can Form 146 Be Filed Online?

Yes. Form 146 can be prepared and filed through the Income Tax Department’s prescribed online facility, subject to the applicable CA authorisation, DSC and verification requirements.

Does Form 146 Replace FEMA and Bank Documentation?

No. Form 146 concerns income-tax certification. Banks may separately require the relevant RBI purpose code, remittance request, invoice, agreement and other documents under applicable FEMA and banking procedures.

Form 146 CA Certification Services by EzyBiz India

Professional Assistance for Indian Businesses and Individuals

EzyBiz India Consulting LLP assists businesses and individuals with Form 146 CA certification and related foreign-remittance tax compliance.

Our services include:

• Form 146 applicability review.
• Examination of agreements, invoices and payment documents.
• Indian income-tax chargeability analysis.
• Review of applicable DTAA provisions.
• Tax Residency Certificate and other documentation review.
• Withholding-tax and grossing-up calculations, where applicable.
• Preparation and electronic certification of Form 146.
• Assistance with Form 145 Part C.
• Foreign-remittance tax advisory.
• Coordination of related FEMA and bank documentation, where required.

We support Indian companies, foreign subsidiaries, importers, service recipients, NRIs and other taxpayers making relevant cross-border payments.

Need a Form 146 CA Certificate for an upcoming remittance? Contact our team for transaction-specific guidance and professional assistance.

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 team

Related Services

• Form 145 and Form 146 Filing Services in India
• Form 145 and Form 146 vs Form 15CA and Form 15CB
• Form 15CA and Form 15CB – Earlier Framework
• FAQs on Form 15CA and Form 15CB
• Step-by-Step Filing Guide for Earlier Forms
• CA Certification for Foreign Purchase Payments

Official External References

• Income Tax Department – Form 146 User Manual
• Income Tax Department – Form 145 User Manual
• Income Tax Department – Form 146 FAQs
• Income-tax Rules, 2026 – Official Notification
• 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 regarding Form 146 CA certification and foreign-remittance compliance under the Income-tax Act, 2025 and Income-tax Rules, 2026. The applicable requirements depend on the nature of the remittance, chargeability of income, relevant statutory provisions, DTAA conditions, supporting documentation and the law governing the relevant transaction. Professional advice should be obtained before determining withholding tax, claiming treaty relief or making foreign remittances. The article does not constitute a transaction-specific tax opinion or Chartered Accountant certificate. Statutory provisions, rules and portal procedures may change.