If you are an NRI repatriating sale proceeds, an Indian business paying a foreign vendor, or a CA running the remittance pipeline for either — the form numbers you have been using since 2013 changed on 1 April 2026. Forms 15CA and 15CB were renumbered to Forms 145 and 146 under the Income Tax Act 2025 and Income Tax Rules 2026. The substance of what each form does is largely unchanged, but the bank screens, the e-filing portal, and the search results you find online are now in a confusing transition period. This guide is for both old and new numbering.
What changed on 1 April 2026
| Old (pre-Apr 2026) | New (Apr 2026 onwards) | Purpose |
|---|---|---|
| Form 15CA | Form 145 | Declaration by the remitter (payer) of foreign remittance |
| Form 15CB | Form 146 | Certificate by a Chartered Accountant verifying the tax position |
| Rule 37BB | Rule under IT Rules 2026 | Statutory basis for the forms (substantively unchanged) |
| Section 195(6) | Section 195(6) (continues) | The substantive provision triggering the certification |
Form 145 — the declaration by remitter
Form 145 (the old Form 15CA) is the online declaration that the payer makes to the Income Tax Department, declaring that they are about to remit money to a non-resident and that the appropriate tax has been deducted, or that no tax is deductible. It is filed by the remitter — not by the CA.
- Filed online on the e-filing portal (incometax.gov.in) by the remitter.
- Four parts (A, B, C, D) corresponding to different remittance categories — small remittances, taxable above threshold, DTAA-relieved, and exempt categories.
- Generates an Acknowledgement Number that the bank quotes when processing the remittance.
- Must reference the corresponding Form 146 (CA certificate) wherever applicable.
Form 146 — the CA certificate
Form 146 (the old Form 15CB) is the certificate signed by a Chartered Accountant confirming the taxability of the proposed remittance, the rate of tax applicable, and the section under which it has been computed. It is the CA's professional certification, signed with DSC, that the tax position is correct.
- Filed by the CA on the e-filing portal before the remitter files Form 145.
- CA must verify: nature of payment, taxability under the Income Tax Act, applicability of relevant DTAA article, TDS rate after treaty benefit, whether a TRC and Form 10F are on file.
- The CA's UDIN is generated against Form 146 — a unique number that can be verified by the bank, the recipient and the Income Tax Department.
- Form 146 is mandatory before Form 145 Part C is filed (taxable remittances above ₹5 lakh).
The ₹5 lakh threshold rule
Both the old and the new regime carry a ₹5 lakh threshold (per FY, per remittance combination) that decides whether you need only Form 145 or both Form 145 + Form 146:
| Remittance scenario | Form 145 (15CA)? | Form 146 (15CB)? |
|---|---|---|
| Remittance not taxable in India (e.g. small gift, exempt under Section 10) | Part D only | Not required |
| Aggregate remittance ≤ ₹5 lakh in FY (taxable) | Part A only | Not required |
| Aggregate remittance > ₹5 lakh (taxable, not under DTAA relief) | Part C | Required |
| Tax-deductible remittance with DTAA relief — any amount | Part B | Required to claim treaty rate |
| Remittance specifically listed as exempt under Rule (e.g. listed personal use) | Not required | Not required |
When you actually need Form 145 / 146
Common, real-world scenarios that trigger Form 145 / 146 (formerly 15CA / 15CB):
- NRI repatriating sale proceeds of Indian property to their NRE/foreign account (post-TDS).
- Indian company paying a foreign vendor for software, design, technical or professional services.
- Indian company paying foreign royalty, fees for technical services, interest or dividend.
- NRI repatriating annual NRO balance up to USD 1 million per FY.
- Indian business paying a non-resident broker, commission agent or consultant.
- Reimbursements to a foreign group company that exceed the ₹5 lakh threshold.
- Payments to foreign branches of Indian companies (intra-group cross-border).
Process — from invoice to remittance
- Remitter shares full payment details with the CA — invoice, agreement, recipient PAN (if any), TRC, Form 10F (for DTAA), purpose code.
- CA verifies taxability under the Income Tax Act 2025 and the applicable DTAA.
- CA files Form 146 on the e-filing portal, signs with DSC, generates UDIN.
- Remitter files Form 145 (referencing Form 146 acknowledgement number where applicable).
- Both forms are submitted to the AD bank with the FEMA outward remittance declaration.
- Bank processes the remittance — typically 1-3 working days from a complete pack.
- Recipient receives the funds; CA retains copies for 8 years per record-retention rules.
What banks reject
- Form 146 missing UDIN — banks now verify UDIN online before releasing funds.
- Mismatch between Form 145 stated TDS amount and the certificate in Form 146.
- DTAA rate claimed without supporting TRC and Form 10F.
- Wrong purpose code in the FEMA declaration vs the section claimed in Form 146.
- Form 145 Part A filed when the threshold is actually breached and Part C / 146 are required.
- Stale Form 146 — banks reject certificates older than 30 days for the same remittance window.
Old-vs-new transition
The Income Tax Department portal hosts Form 145 explicitly as 'Payments to Non-Residents/Foreign Company'. Some banks and corporate finance teams still informally call them 15CA / 15CB — and that is fine through 2026 as the system catches up. Practitioner sites have started using bridging phrases like 'Form 145 146 (Earlier Forms 15CA 15CB)' to avoid confusion. Pujara & Co. handles both old and new — what matters is that the underlying tax certification is correct, regardless of the form number on the cover sheet.
Frequently Asked Questions
Is Form 15CB still valid after 1 April 2026?
Form 146 is the new official name from 1 April 2026 onwards. Historical Form 15CB filings before that date remain valid as records. For new remittances after 1 April 2026, banks will expect Form 146 — though many still informally accept 'Form 15CB' interchangeably during the transition period.
When is Form 146 (15CB) mandatory?
When aggregate taxable remittance in a financial year exceeds ₹5 lakh, OR when you are claiming DTAA-reduced TDS at any value. The CA certificate is the document the bank uses to verify the tax position before releasing funds.
Who can file Form 146?
Only a Chartered Accountant in practice, holding a valid Certificate of Practice from ICAI, with a UDIN generation facility on the e-filing portal. Tax preparers, accountants without ICAI membership, and lawyers cannot file Form 146.
What is the typical fee for Form 146?
Varies by transaction complexity — from ₹2,500 for a straightforward NRO repatriation under DTAA to ₹15,000+ for a complex multi-country payment requiring deep treaty analysis. At Pujara & Co. NRO repatriation packs start from ₹3,500 inclusive of Form 145 + 146.
How long does Form 146 take to issue?
From complete documentation, typically 1-2 working days. Complex DTAA cases (multiple income heads, hybrid instruments, royalty vs FTS classification) can take up to 5 days. We schedule remittance windows accordingly.
Do I need Form 145 / 146 for NRE-account remittances back to my foreign account?
NRE balances are freely repatriable without Form 146 because they were funded by foreign earnings already remitted from abroad. The ₹5 lakh threshold and Form 146 apply specifically to NRO repatriation (Indian-source income) and to Indian-business payments to non-residents.
Need Form 145 + Form 146 for a remittance? Pujara & Co handles the full pack.
Cross-border CA practice since 2014. NRO repatriation, foreign vendor payments, DTAA verification, UDIN-stamped Form 146 — typically delivered in 1-2 working days from complete documentation.
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