For foreign remittances made on or after 1 April 2026, Indian taxpayers and finance teams should stop treating Form 15CA and Form 15CB as the current filing pair. Under the Income Tax Act, 2025 framework, the corresponding remittance forms are Form 145 and Form 146. The Income Tax Department's transition FAQ confirms that Forms 145 and 146 apply to remittances made on or after 1 April 2026.
What are Form 145 and Form 146?
Form 145 is the information statement furnished by the person responsible for making a payment to a non-resident, not being a company, or to a foreign company. The Department's Form 145 user manual states that it is filed for each remittance before the amount is remitted.
Form 146 is the accountant's certificate used in specified taxable-remittance cases. According to the official Form 146 user manual, the CA examines the remittance, including taxability under the Act and the applicable Double Taxation Avoidance Agreement, and certifies tax-deduction details.
Which part of Form 145 should be used?
Form 145 has four parts. Choosing the correct part depends mainly on whether the remittance is taxable, the aggregate amount during the tax year and whether an Assessing Officer certificate or a CA certificate has been obtained.
- Part A: for a taxable remittance where the remittance or aggregate of such remittances does not exceed ₹5 lakh during the tax year.
- Part B: for a taxable remittance exceeding the ₹5 lakh aggregate threshold where the prescribed certificate under the relevant Assessing Officer route has been obtained.
- Part C: for a taxable remittance exceeding the ₹5 lakh aggregate threshold where a certificate in Form 146 from an accountant has been obtained.
- Part D: for a remittance that is not taxable under the Act, other than payments covered by the exclusions referred to in the applicable rules.
The practical point is that the ₹5 lakh test is not merely a per-transaction test. The official manual describes it by reference to the remittance or the aggregate of such remittances during the tax year.
When is Form 146 required?
Form 146 is not required for every foreign payment. The official Form 146 manual describes it as the accountant's certificate for a payment, or aggregate of payments, exceeding ₹5 lakh in the tax year where the payment is taxable and the Form 145 Part C route is being used.
For Part C, Form 146 comes first. The Form 145 manual states that Part C information is prefilled using the ARN of the filed Form 146. In practice, the taxpayer should therefore assign Form 146 to the CA, the CA should complete and verify it, and the taxpayer should then use the filed Form 146 details while completing Form 145 Part C.
What does the CA examine in Form 146?
The Form 146 manual divides the certificate into panels covering the remitter, remittee, remittance, taxability under domestic law, taxability under the DTAA, tax deducted at source and verification. This makes Form 146 more than a procedural attachment: the CA is certifying a tax determination around the remittance.
Where treaty relief is relevant, finance teams should give the CA the agreement, invoice, nature-of-service details, residency documentation and other evidence needed to analyse the payment. A bank description such as “consultancy fee” or “software payment” is not a substitute for examining the actual contractual rights and services.
Worked example
Assume an Indian company proposes to remit ₹8 lakh to a foreign service provider during the tax year and concludes, after examining domestic law and the applicable treaty, that the payment is taxable in India. If the company does not use the Assessing Officer certificate route described for Part B, it would ordinarily need the accountant-certificate route: the CA files Form 146 and the remitter then files Part C of Form 145 before making the remittance.
Now assume instead that a payment is not taxable under the Act. The Form 145 framework provides Part D for non-taxable remittances, subject to the exclusions in the applicable rules. The key decision is therefore taxability first, not simply the size of the remittance.
What happened to Forms 15CA and 15CB?
The old forms remain relevant when reviewing remittances made under the earlier law. The Income Tax Department's transition FAQ states that Forms 15CA and 15CB submitted for remittances made before 31 March 2026 continue to remain valid after commencement of the new Act, provided the remittance actually took place on or before the date stated in the form. For remittances on or after 1 April 2026, Forms 145 and 146 apply.
This cut-off matters for audit files and bank documentation. A team should not mechanically replace historical Form 15CA/15CB references in records relating to pre-April 2026 remittances, nor should it use those old forms for a new remittance merely because an internal SOP has not yet been updated.
Practical checklist before a foreign remittance
- Identify the remittance date: determine whether the payment falls under the post-1 April 2026 Form 145/146 framework.
- Determine taxability: examine domestic-law chargeability and, where relevant, treaty provisions before selecting the Form 145 part.
- Aggregate payments: check payments to which the ₹5 lakh tax-year threshold applies rather than looking only at the current invoice.
- Choose Part A, B, C or D: match the facts to the official Form 145 classification.
- Assign Form 146 to the CA where Part C applies: ensure the CA is registered on the e-Filing portal and has a valid registered DSC.
- Prepare evidence: keep the contract, invoice, tax-residency and treaty documents, tax computation and TDS evidence relevant to the conclusion.
- File before remittance: the Form 145 manual expressly states that the form is filed before the amount is remitted.
Online and offline filing
The Income Tax Department provides both online filing guidance and an offline utility. Its Income Tax Act, 2025 forms download page lists a common offline utility for Forms 145 and 146. Teams using automated payment workflows should update their compliance checklist and maker-checker controls to reference the new form numbers.
Key takeaway
For remittances made on or after 1 April 2026, Form 145 and Form 146 are the current successors to Form 15CA and Form 15CB. Start with taxability, then apply the ₹5 lakh aggregate threshold and choose the correct Form 145 part. Where Part C applies, the CA must complete Form 146 first. Updating remittance SOPs, bank-document checklists and internal tax controls to the new form numbers can prevent avoidable processing errors.
