Form 145 Due Date in 2026: When to File Before Foreign Remittance

Direct answer: Form 145 does not have a calendar due date such as month-end or year-end. For remittances made on or after 1 April 2026, it must be furnished before the payment is remitted to the non-resident or foreign company. If Part C applies, the Chartered Accountant must first file Form 146 so that its ARN/details can feed into Form 145 Part C.

Why this timing question matters in 2026

Form 145 replaces Form 15CA for remittances made on or after 1 April 2026 under the Income-tax Act, 2025 and Income-tax Rules, 2026. Businesses that still think in terms of “15CA/15CB due dates” can miss the operational point: the compliance trigger is the remittance itself. The form is designed to be completed transaction-by-transaction before the bank or authorised dealer processes the payment.

For finance teams, this means Form 145 should sit inside the payment-release workflow, not as a post-payment tax form. The taxability review, TDS computation, DTAA documentation and—where required—Form 146 should be completed before treasury releases funds.

1. What is the due date for Form 145?

There is no fixed annual, quarterly or monthly due date for Form 145. Rule 220 requires the information to be furnished and submitted to the authorised dealer before remitting the payment. The Income Tax Department’s Form 145 user manual also states that the form is filed for each remittance before the amount is remitted.

Practical rule: do not ask “Is Form 145 due by a certain date?” Ask “Has Form 145 been successfully filed and acknowledged before this specific outward remittance is released?”

2. Which law applies for remittances made after 1 April 2026?

The Income Tax Department’s transition guidance confirms that remittances made on or after 1 April 2026 use Forms 145 and 146 under the new Act and Rules. The procedural form follows the law in force on the date of remittance. However, where the underlying income accrued before 1 April 2026, the taxability of that income may still need to be tested under the law applicable to the year of accrual.

This distinction matters for old invoices paid after 1 April 2026: the form and reporting workflow may be new, while the underlying tax analysis can still involve the Income-tax Act, 1961.

3. Form 145 Part A, B, C or D: timing changes with the route

Part A generally applies where the remittance is chargeable to tax and the amount or aggregate of such remittances during the tax year does not exceed ₹5 lakh.

Part B generally applies where the taxable remittance exceeds ₹5 lakh and the payer has obtained the relevant certificate/order from the Assessing Officer under section 395(1) or 395(2).

Part C generally applies where the taxable remittance exceeds ₹5 lakh and a Chartered Accountant has issued Form 146. In this route, Form 146 must be filed first because Form 145 Part C uses the filed Form 146 details.

Part D applies to non-taxable remittances that still require reporting, other than specified payments excluded under Rule 220(3).

For a detailed Part A/B/C/D decision guide, see our related article: Form 145 Part A vs B vs C vs D: Which Part Applies in 2026?

4. When must Form 146 be filed?

Form 146 does not have a separate fixed calendar due date. It is an accountant’s certificate used where the prescribed Part C conditions are satisfied. Operationally, it must be completed before the taxpayer files Form 145 Part C and before the remittance is released.

The Income Tax Department states that Form 146 is required for a taxable payment where the remittance or aggregate of such payments exceeds ₹5 lakh during the tax year, unless the payment is being handled through the Assessing Officer certificate route reflected in Part B.

For the CA-certificate workflow, see: When Is Form 146 Required in 2026?

5. A practical payment-release timeline

T-5 to T-3 working days: finance identifies the foreign payment, recipient, invoice, nature of service/goods, DTAA position, permanent establishment risk, beneficial ownership documents and RBI purpose code.

T-3 to T-2 working days: tax team determines chargeability and TDS. If Part C is expected, Form 146 is assigned to the Chartered Accountant with agreement, invoice, TRC/Form 41 or other residency evidence, tax computation and supporting documents.

T-2 to T-1 working days: CA files Form 146 where applicable. The taxpayer then files the correct part of Form 145, completes e-verification and records the acknowledgement/transaction details.

Payment day: treasury gives the filed Form 145 and supporting tax documents to the authorised dealer and releases the remittance only after tax and reporting checks are complete.

6. What if the payment amount or date changes after Form 145 is prepared?

Form 145 captures the proposed date and particulars of the remittance. Therefore, treasury should compare the actual payment instruction with the filed form before release. If the amount, recipient, nature, tax treatment or other material particulars change, the tax team should not assume the earlier form remains suitable. The safest control is to revalidate the filing with the authorised dealer and portal process before remittance, and make a fresh/correct filing where required.

The Department’s transition FAQ expressly states, for legacy Forms 15CA/15CB filed for pre-1 April 2026 remittances, that the forms were valid up to the proposed remittance date and fresh forms were required if the remittance did not occur within that period. For Form 145, the current rule itself still makes pre-remittance accuracy the core control.

7. Common timing mistakes

Mistake 1: filing Form 145 after the bank has already processed the remittance. This reverses the statutory sequence.

Mistake 2: starting Form 146 only on the payment date. Part C cannot be completed efficiently unless the CA review and certification are already done.

Mistake 3: treating every remittance above ₹5 lakh as automatically requiring Form 146. Part B may apply where the relevant Assessing Officer certificate/order has been obtained; Rule 220(3) also excludes specified categories from Form 145.

Mistake 4: ignoring aggregate payments during the tax year. The ₹5 lakh test is not always a single-invoice test; aggregation matters.

Mistake 5: reusing an old taxability memo when the contract, DTAA position, recipient status or nature of payment has changed.

8. Pre-remittance checklist for finance teams

• Identify the exact payee and country of residence. • Confirm the nature of remittance and RBI purpose code. • Determine whether the sum is chargeable to tax in India. • Check the aggregate remittances to that payee/category for the tax year where relevant. • Determine whether Part A, B, C or D applies. • Obtain Form 146 first if Part C applies. • Complete TDS payment and documentation as applicable. • File and e-verify Form 145 before remittance. • Match the filed particulars with the final bank instruction. • Preserve the acknowledgement, Form 146/AO certificate, tax computation, invoice, agreement and residency/DTAA evidence.

9. Worked example

Assume an Indian company proposes to pay ₹12 lakh to a non-resident consultant for services. The tax team concludes that the payment is chargeable to tax in India and the company has not obtained an Assessing Officer certificate under section 395. Because the taxable remittance exceeds ₹5 lakh, the company should arrange Form 146 from its Chartered Accountant, then file Form 145 Part C, e-verify it and provide the required information to the authorised dealer before the ₹12 lakh remittance is released.

If, instead, the remittance falls within a Rule 220(3) excluded purpose and is not chargeable in India, the Form 145 requirement may not arise at all. Classification should therefore precede form filing.

For the exemption analysis, see: When Is Form 145 Not Required in 2026?

10. Frequently asked questions

Is Form 145 filed once a year?

No. It is a remittance-linked information form and is filed for each remittance where the reporting requirement applies.

Can Form 145 be filed after payment?

The statutory workflow requires it before remittance. Finance teams should therefore make successful filing and e-verification a payment-release condition.

Does every payment above ₹5 lakh require Form 146?

No. Form 146 is relevant to the Part C route for taxable remittances above the threshold. A valid Assessing Officer certificate/order can place the case in Part B, and specified Rule 220(3) payments can be outside Form 145 altogether.

What replaced Form 15CA and Form 15CB from 1 April 2026?

For remittances made on or after 1 April 2026, Form 145 replaces Form 15CA and Form 146 replaces Form 15CB under the new framework.

What is the safest internal control?

Block outward payment until the taxability memo, TDS position, applicable Form 145 part, Form 146/AO certificate where needed, and final e-filing acknowledgement are complete and match the bank instruction.

Primary sources

Income Tax Department — Form 145 User Manual

Income Tax Department — Form 146 User Manual

Income Tax Department — Rule 220, Income-tax Rules, 2026

Need help with a foreign remittance?

PGT & Associates assists businesses with foreign-remittance taxability, DTAA analysis, TDS, Form 145/146 documentation and cross-border compliance. For professional assistance, visit PGT & Associates.

Disclaimer: This article is for general professional information and does not constitute legal, tax or investment advice. Foreign-remittance taxability depends on the facts, contract, recipient status, applicable treaty, source rules and current law. Obtain transaction-specific advice before remitting funds.