From April 2026, the Income Tax Department is introducing a new system for reporting foreign remittances. Form 145 and Form 146 will replace the earlier Form 15CA and Form 15CB.
This change aims to simplify the process, make it more digital, reduce paperwork, and improve transparency in reporting foreign transactions.

Old System: Form 15CA & 15CB
Under the earlier system:
- Form 15CA was a self-declaration filed by the person making the payment
- Form 15CB was a certificate issued by a Chartered Accountant
These forms ensured that the payer followed Section 195 of the Income-tax Act, 1961, which deals with TDS on payments made to non-residents.
Why Changes Were Needed in Foreign Remittance Rules
Over time, some problems were noticed in the old system:
- Same information had to be entered in multiple forms
- Heavy reliance on manual processes and professionals
- No real-time checks or validation
- Higher compliance burden for businesses
- Limited connection with banking and tax systems
To overcome these issues, a more streamlined and technology-based system has now been introduced.

Introduction of Form 145 & Form 146
Form 145 – Foreign Remittance Form
- Filed by the person making the payment (remitter)
- Includes complete details of the transaction
- Connected with the income tax system for easy checking and validation
Form 146 – CA Certificate
- Issued by a Chartered Accountant
- Confirms taxability, TDS details, and DTAA benefits (if applicable)
- Replaces Form 15CB with more detailed reporting
Key Features of the New Forms
- Fully online filing process
- Some details are automatically filled from income tax records
- Built-in checks to reduce errors
- Easier tracking of foreign payments
- Better aligned with modern tax and global compliance standards
Applicability & Scope
Form 145 and Form 146 are used in the following cases:
- When payments are made to non-residents
- When money is sent outside India
- When the transaction is taxable under Indian law
When These Forms Are Not Required
- If the remittance is not taxable
- If it falls under specific exemption categories
- If it is listed under RBI’s exempt remittance list
When is Form 145 Required?
Form 145 must be filed:
- Before sending money outside India
- For taxable payments and some non-taxable transactions
- In all cases where reporting is required under income tax rules
When is Form 146 (CA Certificate) Required?
Form 146 is needed in the following situations:
- When taxability of the payment needs to be determined
- When DTAA benefits are being claimed
- For high-value or complex transactions
- When a professional certification from a Chartered Accountant is required
Simple Steps to File Form 145
- Log in to the Income Tax e-Filing portal
- Go to e-File → Foreign Remittance Compliance
- Select Form 145
- Enter details like payer, payee, nature, and amount of payment
- Upload Form 146 if required
- Check all details using system validation
- Submit the form using DSC or EVC
- Download the acknowledgement for your records
Documents & Details Required
- PAN of the person making the payment
- Details of the foreign recipient
- Nature and purpose of the remittance
- Copy of invoice or agreement
- Tax Residency Certificate (TRC), if applicable
- DTAA calculation (if benefit is claimed)
- TDS calculation details
These details help ensure correct reporting and smooth processing of foreign payments.

Key Compliance Points to Remember
- Correctly identify the nature of the remittance
- Deduct TDS properly as per Section 195
- Keep all supporting documents ready for verification
- Match remittance details with your books of accounts
- Ensure CA certification reflects the actual transaction
Impact on Businesses & Professionals
For Businesses:
- Simpler compliance process
- Faster remittance processing
- Reduced chances of rejection
For Chartered Accountants:
- Higher responsibility in certification
- Need for more detailed analysis
- Greater reliance on professional judgment
14. Penalties & Consequences of Non-Compliance
Failure to comply may result in:
- Penalties under the Income Tax Act
- Disallowance of expenses under Section 40(a)(i)
- Delay or rejection of payments by banks
- Notices or scrutiny from the tax department
Practical Examples
Case 1: Payment for Technical Services (USA)
- Taxable in India
- TDS must be deducted
- Both Form 145 and Form 146 are required
Case 2: Import of Goods
- Usually not taxable
- Form 145 may be required for reporting
- Form 146 is generally not needed
Case 3: Royalty Payment with DTAA Benefit
- Lower tax rate is claimed under DTAA
- Form 146 is required for certification

Conclusion
The introduction of Form 145 and Form 146 brings a more clear and efficient system for handling foreign remittances in India. It improves transparency and simplifies the reporting process.
To adapt to this system, businesses should:
- Keep all required documents ready
- Ensure correct tax calculation on remittances
- Work closely with professionals for proper compliance
Following these steps will help in smooth and hassle-free foreign transactions.
Disclaimer: The content on this website is for informational purposes only and does not constitute legal, financial, or professional advice. Please consult qualified experts before acting on any information. K M GATECHA & CO LLP accepts no liability for errors, omissions, or outcomes from the use of this content. This site is not an advertisement or solicitation.
Need Help?
Frequently Asked Questions (FAQs)
Q1. From when are Form 145 & 146 applicable?
They are applicable from April 2026 onwards.
Q2. Are Form 15CA and 15CB still valid?
No, they have been replaced by Form 145 and Form 146.
Q3. Is Form 146 required in every case?
No, it is required only in cases where certification is needed.
Q4. Who files Form 145?
The person making the foreign payment (remitter) files Form 145.
Q5. Can money be sent abroad without filing Form 145?
Generally, no. Banks may not process the remittance without it.
Q6. What is the role of a Chartered Accountant?
A Chartered Accountant certifies taxability, TDS details, and DTAA benefits through Form 146.
Q7. Is there any penalty for incorrect filing?
Yes, penalties and disallowance of expenses may apply for wrong or incomplete filing.
Q8. Do exempt transactions also need to be reported?
Some exempt transactions may still need to be reported under Form 145, depending on the rules.
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