Why Have Form 15CA and Form 15CB Been Replaced?

The change comes as part of the transition to the Income-tax Act, 2025, which reorganises and renumbers various tax provisions and compliance references.

As part of this shift:

• Form 145 replaces Form 15CA
• Form 146 replaces Form 15CB

The objective is primarily legislative alignment and procedural standardisation under the new tax framework.

For most taxpayers, this means:

• Similar remittance disclosures
• Similar Chartered Accountant certification requirements where applicable
• Similar documentation expectations
• Similar taxability assessments before remitting funds abroad

While the overall compliance intent remains familiar, the new forms (form 145 and form 146) also introduce certain procedural changes that may require additional preparation.

Important Update: Form 145 and Form 146 Are More Than Just a Name Change

Although the shift from Form 15CA and Form 15CB to Form 145 and Form 146 may appear simple, it is not purely cosmetic.

The updated framework introduces several practical changes, including:

• New information fields in Form 145
• Updated certification requirements in Form 146
• System-generated acknowledgement references replacing certain older certificate identifiers
• Transition rules determining whether old or new forms apply

Businesses and remitters should avoid assuming that the filing process is entirely unchanged.

What Is Form 145?

Form 145 is the self-declaration form submitted before certain foreign remittances are made from India.

It is generally filed by the remitter and includes information such as:

• Remitter details
• Recipient details
• Nature and purpose of remittance
• Amount being remitted
• Applicable tax provisions
• Tax deducted or exemption details

The purpose of Form 145 is to ensure that appropriate tax compliance has been considered before the authorised dealer bank processes the remittance.

This form is typically filed electronically through the Income Tax portal.

What Is New in Form 145?

Compared to the earlier Form 15CA, Form 145 appears to require more detailed remittance-related information.

Additional fields may include:

• Tax Identification Number (TIN) of the foreign recipient
• Recipient address details
• IFSC of the remitter’s bank
• Authorised Dealer (AD) bank details
• Purpose sub-code for the remittance

This means businesses and individuals may need to gather more complete information before initiating a foreign remittance.

For organisations handling regular overseas payments, internal remittance checklists and ERP workflows may also need updating.

What Is Form 146?

Form 146 is the Chartered Accountant certification that may be required for certain foreign remittances.

It is issued by a practicing Chartered Accountant after reviewing:

• Nature of the transaction
• Taxability under Indian tax law
• DTAA implications, where relevant
• Applicable withholding obligations
• Supporting documents and agreements

The Chartered Accountant certifies whether the remittance complies with applicable tax provisions and whether taxes have been appropriately deducted, where required.

This continues to be an important professional compliance safeguard.

What Is New in Form 146?

Form 146 introduces some procedural refinements in how CA certification is recorded and verified.

Important changes include:

• A system-generated acknowledgement receipt number replacing the CA’s internal certificate number
• Mandatory inclusion of:
  
  • UDIN
  • Firm Registration Number (FRN)
  • Member Registration Number

These changes aim to improve standardisation and traceability of certification.

For remitters, this makes early coordination with the certifying Chartered Accountant even more important.

What Is the Difference Between Form 145 and Form 146?

While the two forms are connected, they serve different purposes.

In many cases, Form 145 may be sufficient, while Form 146 is required only where additional CA certification is needed.

Has the Foreign Remittance Process Changed?

For most practical purposes, the overall remittance process remains broadly similar.

Typical steps may still include:

• Determining whether the remittance is taxable
• Assessing whether Chartered Accountant certification is required
• Preparing supporting documents
• Filing Form 145
• Obtaining Form 146, where applicable
• Submitting documents to the authorised dealer bank
• Completing the foreign remittance

The main change for many taxpayers is adapting to the updated forms form 145 and form 146 and procedural requirements.

Transition Rules: Which Form Applies and When?

One of the most important practical questions is whether the old or new forms should be used.

Broadly:

For tax deducted on or before 31 March 2026

• Existing rules continue to apply
• Form 15CA and Form 15CB may still be relevant

For tax deducted on or after 1 April 2026

• The new law applies
• Form 145 and Form 146 should be used

During the FY 2026-27 transition period, both old and new references may continue to appear in discussions, internal systems, and bank communications.

Careful review before filing can help avoid confusion or delays.

Who Needs to File Form 145 or Form 146?

These forms commonly arise in situations such as:

• Payment to foreign vendors
• Import of services
• Royalty or technical service payments
• Investment-related remittances
• Property sale proceeds remitted abroad
• Rental income remittances
• NRO to NRE transfers
• Other NRI outward remittances

Whether both forms are required depends on the nature, amount, and tax treatment of the transaction.

Practical Steps to Prepare for Form 145 and Form 146

To avoid delays in foreign remittance processing, taxpayers and businesses may benefit from preparing early.

Recommended steps include:

• Update internal remittance documentation templates
• Collect additional foreign recipient details such as TIN and address
• Coordinate early with your Chartered Accountant for Form 146 certification
• Review ERP or treasury systems for updated form references
• Monitor CBDT notifications for final electronic filing procedures
• Verify which legal regime applies based on the remittance date

Small preparation steps now can help reduce filing issues later.

Common Challenges While Filing Form 145 and Form 146

Although the process may appear straightforward, common issues can include:

• Incorrect remittance classification
• Misunderstanding taxability
• DTAA interpretation errors
• Missing supporting documents
• Delays in Chartered Accountant certification
• Bank rejection due to documentation gaps
• Filing errors on the portal

Careful review of form 145 and form 146 before submission can help avoid repeated filings or remittance delays.

FAQ About Form 145 and Form 146

What replaces Form 15CA?

Form 15CA has been replaced by Form 145 under the new Income-tax framework.

What replaces Form 15CB?

Form 15CB has been replaced by Form 146.

Is the filing process for form 145 and form 146 completely different now?

No. The overall compliance framework remains broadly similar, but certain procedural changes and additional information requirements now apply.

Do all foreign remittances require Form 146?

No. Only specific transactions require Chartered Accountant certification.

Can banks still refer to Form 15CA and Form 15CB?

During the transition period, some institutions may continue using older terminology informally, even though the updated forms apply under the new law.

Will Form 145 require more information than Form 15CA?

Yes, based on currently available guidance, additional fields such as TIN, address, bank details, and remittance sub-codes may be required.

Need Clarity on Form 145 or Form 146?

Foreign remittance compliance can be straightforward when the tax position and documentation are clear, but filing errors can lead to delays or repeated submissions.

A careful review of the transaction, applicable tax provisions, and documentation requirements can help ensure the remittance process moves smoothly.

If you are preparing a remittance and need clarity on whether Form 145, Form 146, or both may apply, early professional guidance can often save significant time and effort.