Form 145 and Form 146 for Foreign Remittances: A Complete Business Guide

The way Indian businesses report and tax outbound payments to non-residents changes materially from 1 April 2026. The Income-tax Act, 2025 and the Income-tax Rules, 2026, replace the Income-tax Act, 1961, and the long-familiar Form 15CA and Form 15CB are replaced by Form 145and Form 146, respectively. The new forms are more than a renumbering; they are designed to capture more structured data and increase reporting precision around cross-border payments. 

What Are Form 145 and Form 146? 

Under Rule 220 of the Income-tax Rules, 2026, prescribed information is to be furnished before qualifying remittances to a non-resident (other than a company) or to a foreign company — subject to the rule’s scope and the carve-outs in Rule 220(3). That information is now furnished on Form 145, the digital self-declaration that captures details of the remitter, the remittee, the authorised dealer bank, the nature of the payment and the TDS deducted. It replaces Form 15CA and is the primary disclosure form the department uses to assess whether the payment is chargeable to tax in the hands of the foreign recipient. Form 145 is event-based — it is filed before each qualifying remittance, not on an annual or consolidated basis.

The substantive obligation to deduct tax flows from Section 393 of the Income-tax Act, 2025, which corresponds to the earlier withholding framework under Section 195 of the 1961 Act — any sum payable to a non-resident that is taxable in India must suffer TDS at the applicable rate. To verify that this rate has been correctly determined under the Act and any relevant Double Taxation Avoidance Agreement (DTAA), a practising Chartered Accountant issues Form 146, the accountant’s certificate that replaces Form 15CB. Form 146 must carry a valid UDIN and is issued by an “accountant” as defined in Section 515(3)(b) of the new Act. In practice, the taxpayer first assigns Form 146 to the CA on the e-filing portal; the CA then files Form 146 using a registered Digital Signature Certificate (DSC), and the resulting acknowledgement number is used by the remitter to file Part C of Form 145.

What Are the Key Compliance Changes in Form 145?

The biggest change is the move away from unstructured remittance descriptions. Form 145 requires remitters to pick from a structured drop-down of nature-of-remittance categories aligned with RBI’s Purpose Code framework — the exact category count and mapping should be checked against the live utility before being relied on for SOPs. The intent of the change is clear: a structured classification reduces the risk of a payment for “Fees for Technical Services” being passed off as ordinary business income, since wrong categorisation may now create filing and tax-risk issues at both the portal and the banking channel.

The form also asks for more structured information about the foreign vendor (the remittee) and the authorised dealer handling the transaction, with cross-verification possible against related disclosure forms (such as Form 147 filed by Authorised Dealers). The exact list of mandatory fields, however, should be confirmed from the live e-filing portal or the offline utility before businesses reconfigure their vendor master, because the schema can be updated by the department over time.

When is a CA Certificate (Form 146) Required? ⚖️

A CA certificate is not needed for every cross-border payment — its requirement turns on whether the remittance is taxable in India and on the rupee value of payments made to that recipient during the year. In broad terms, Form 146 becomes mandatory only when the payment is taxable, the aggregate of remittances to that payee crosses ₹5 lakh in the tax year, and no certificate has been obtained from the Assessing Officer. Form 145 itself is structured into four parts that map directly to these situations:

TDS and CA-Certification Matrix

Before initiating any overseas transfer, the accounts payable team can use the snapshot below to decide which part of Form 145 to file and whether a CA certificate is, in fact,t needed.

Note: Where treaty relief is claimed under a DTAA, the position should be tested for eligibility and supported by documents such as a Tax Residency Certificate (TRC) and Form 41, in addition to the Act-rate analysis carried out in Form 146.

Conclusion

The shift from 15CA/15CB to Form 145/Form 146 is a major procedural change to the foreign-remittance reporting framework — structured remittance classifications, UDIN-tagged CA certificates, and more system-led validation together raise the bar for accuracy in cross-border reporting. The practical action for every finance team is straightforward: review vendor and remittance master data, capture TIN and country-of-residence details where available, and align internal service-classification language with the RBI Purpose Code framework before the 1 April 2026 effective date.

Frequently Asked Questions

Author Bio

Editorial Team

Setindiabiz Editorial Team is a multidisciplinary collective of Chartered Accountants, Company Secretaries, and Advocates offering authoritative insights on India’s regulatory and business landscape. With decades of experience in compliance, taxation, and advisory, they empower entrepreneurs and enterprises to make informed decisions.