Forms 145 and 146: The New 15CA and 15CB, and the One Question Every Foreign Remittance Starts With

Two payments leave the same bank branch on the same Tuesday morning.

A father in Pune is paying his daughter's first-semester fees to a university in Toronto. Two floors up, a software company is paying a licence fee to a vendor in California. The bank's foreign exchange desk handles both. One of them needs a form from the Income-tax Department and a certificate from a chartered accountant before the money can move. The other needs nothing at all.

The forms used to be called 15CA and 15CB. Since 1 April 2026 they are Form 145 and Form 146, under rule 220 of the Income-tax Rules, 2026. The logic behind them hasn't changed. But it is worth relearning, because the numbers everyone knew by heart are gone.

The new names

• Form 145 is the remitter's declaration, the successor to Form 15CA. It has four parts, A to D.
• Form 146 is the chartered accountant's certificate, the successor to Form 15CB.
• Form 147 is the authorised dealer's quarterly statement of all these remittances, due within fifteen days from the end of each quarter.

The duty itself is in section 397(3)(d) of the Income-tax Act, 2025. Anyone paying a non-resident, or a foreign company, any sum, whether or not chargeable to tax, must furnish information about it in the prescribed form. Tax on the payment is deducted under section 393(2), the successor to section 195.

One question decides everything

The first question rule 220 asks is not how much, but whether the payment is chargeable to tax in India.

If it is not chargeable, most remittances still need Part D of Form 145. But rule 220(3) takes three kinds out altogether:

• a remittance by an individual that needs no prior approval from the Reserve Bank under the Liberalised Remittance Scheme rules;
• a remittance by a Unit of an International Financial Services Centre;
• a remittance whose RBI purpose code is on the specified list of 33, among them imports, investment abroad, business travel, education, medical treatment, gifts, and family maintenance by non-residents.

That is why the father's payment needs nothing. It is an individual's education remittance, and it is on the list twice over.

If it is chargeable, the amount decides the part:

• Part A, where the payments to that payee in the tax year come to ₹5,00,000 or less;
• Part B, above ₹5,00,000, where the Assessing Officer has issued a certificate or order under section 395(1) or (2);
• Part C, above ₹5,00,000 otherwise, with a Form 146 certificate from a chartered accountant.

The software licence, if it is taxable in India as royalty, and above ₹5 lakh for the year, is a Part C case.

What Form 146 actually certifies

The accountant's certificate follows the same logic as 15CB did, field by field.

• Taxability under the Act first, ignoring any treaty: is the remittance chargeable, under which section, how much income, how much tax, at what rate.
• Then the treaty: whether a Tax Residency Certificate has been obtained from the payee, its number, the treaty and the article relied on, and the income and tax as the treaty computes them.
• Grossing up: whether the tax has been grossed up under section 393(10), where the payer bears the tax.

The certificate is only as good as its second half. A treaty rate claimed without the payee's Tax Residency Certificate is a rate the treaty does not allow.

Timing, and what it costs to skip

Rule 220(4) is plain about order: Form 145 is furnished electronically before the remittance, and then given to the authorised dealer. Under section 462, failing to furnish the information, or furnishing it inaccurately, can cost a penalty of ₹1,00,000.

Work out which part

Before the next remittance

• Settle taxability first, under the Act and then under the treaty, before anyone opens the form.
• Keep a running total of payments to each payee for the tax year. The ₹5 lakh line in Part A is for the year, not per payment.
• Collect the payee's Tax Residency Certificate before claiming a treaty rate, together with the information the Rules ask non-residents to give, now in Form 41.
• Check the RBI purpose code against the list of 33 before deciding that nothing is needed.

Where this comes from

Rule 220 and Forms 145 and 146 are from the Income-tax Rules, 2026 as published in the Gazette of India, G.S.R. 198(E), 20 March 2026. The duty to furnish and the penalty are sections 397(3)(d) and 462 of the Income-tax Act, 2025, and the tax on the payment is section 393(2). For every other form that was renumbered, see the new form numbers.