Form 15CA/15CB Is Now Forms 145/146: The 2026 Foreign Remittance Compliance Redesign

Cross-border remittance compliance has not disappeared under the Income-tax Act, 2025—it has been rebuilt. The familiar Form 15CA and Form 15CB framework under Rule 37BB of the Income-tax Rules, 1962 has moved into Forms 145 and 146 under Rule 220 of the Income-tax Rules, 2026. For businesses, finance teams and Chartered Accountants handling payments to non-residents, the change is more than a renumbering exercise: it adds stronger data validation, tighter linkage between the remitter, accountant and authorised dealer, and more explicit risk-analysis fields.

The legal crosswalk: old law to new law

The Income Tax Department's official guidance maps old Form 15CA to Form 145 and old Form 15CB to Form 146. Form 145 corresponds principally to sections 393, 395, 397 and 462 of the Income-tax Act, 2025, while Form 146 corresponds to sections 393 and 463. Both sit under Rule 220 of the Income-tax Rules, 2026. This matters operationally because internal SOPs, engagement letters, ERP checklists and tax-control matrices that still quote section 195, Rule 37BB or Form 15CA/15CB should now be updated for tax years governed by the 2025 Act.

Form 145: the remitter's declaration has become more data-driven

Form 145 remains an event-based declaration to be furnished before a qualifying payment is remitted to a non-resident or foreign company. The Department's guidance confirms that the four-part structure continues: Part A for taxable remittances up to ₹5 lakh during the tax year; Part B for taxable remittances above ₹5 lakh where an Assessing Officer certificate has been obtained; Part C for taxable remittances above ₹5 lakh supported by an accountant's Form 146; and Part D where the remittance is not chargeable to tax. The ₹5 lakh test is therefore still central to deciding the compliance route.

The important changes are in the data architecture. Form 145 now captures the foreign recipient's Tax Identification Number where PAN is unavailable, adds authorised-dealer identification logic, introduces an optional ITDREIN field for cross-verification with the authorised dealer's quarterly reporting, and standardises bank-branch BSR-code capture. The official guidance also states that Aadhaar details have been removed from this workflow and that electronic delivery to the authorised dealer is enabled under the revised Rule 220 framework.

Form 146: greater responsibility for the certifying Chartered Accountant

Form 146 is the accountant's certificate used for a taxable remittance exceeding ₹5 lakh during the tax year where the remitter has not obtained the relevant Assessing Officer certificate and is filing Part C of Form 145. The Department's guidance says the Chartered Accountant must examine chargeability under the Income-tax Act as well as applicable treaty relief. This remains a substantive tax-opinion exercise, not a clerical certificate.

The redesigned Form 146 strengthens authentication and transaction-level detail. It captures the accountant's PAN, Firm Registration Number and UDIN, and the Department specifically notes real-time validation through an ICAI API link. For capital-gains remittances, the form also adds fields covering the date of sale, sale consideration, deemed/full-value consideration where relevant, and date of acquisition. These fields make the certificate easier to reconcile with the underlying transaction and more exposed to data mismatch if the legal analysis and source documents are not aligned.

The operational risk: mismatch across Forms 145, 146 and authorised-dealer reporting

A major theme in the Department's own guidance is reconciliation. It identifies historical mismatch risks caused by manual entry, exchange-rate movement between declaration and actual remittance, duplicate capture and multiple filings for a single transaction. The new design is intended to improve cross-verification between the remitter's Form 145, the accountant's Form 146 and the authorised dealer's Form 147 reporting. That means businesses should treat the three records as one compliance chain rather than three independent filings.

What finance teams and tax advisers should change now

First, redesign the foreign-remittance checklist around the new Act and Rule 220 rather than simply replacing the form number in old templates. Determine chargeability, treaty eligibility, aggregation beyond ₹5 lakh, and whether the case belongs in Part A, B, C or D before the payment reaches the bank. Second, standardise recipient master data so PAN, foreign TIN, TRC, address and treaty-supporting documents are consistent across invoice, contract, Form 145 and Form 146. Third, where Part C applies, complete and upload Form 146 before Form 145 because the acknowledgement of Form 146 is used in the Part C filing workflow. Fourth, reconcile the amount, currency, bank, authorised dealer, purpose code, tax rate and remittance date before the bank processes the payment. Fifth, preserve the taxability memo, treaty analysis, invoice, agreement, TRC, Form 41 where applicable, Form 146, UDIN evidence, Form 145 acknowledgement and bank advice as a single audit trail.

Penalty and governance implications

The compliance risk is not theoretical. The Department's Form 145 FAQ states that failure to furnish the form, or furnishing inaccurate information, can attract a penalty of up to ₹1 lakh under section 462 of the Income-tax Act, 2025. Form 145 cannot be edited after submission, although the official FAQ allows withdrawal within seven days; a linked Form 146 is correspondingly updated where the Part C filing is withdrawn. That makes pre-filing review more important than post-filing correction.

Practical takeaway

The 2026 framework preserves the familiar logic of non-resident remittance certification but moves it into a more integrated compliance environment. The real change is traceability: foreign TIN, authorised-dealer data, BSR code, ITDREIN, FRN and UDIN are all designed to make the transaction easier to match across systems. Businesses with recurring foreign payments should therefore treat Forms 145 and 146 as part of their payment-control architecture, not as end-stage forms completed just before remittance.

Primary references

This article is based on the Income Tax Department's official Income-tax Act, 2025 / Income-tax Rules, 2026 resources, the official FAQ and Guidance Note for Form 145 (earlier Form 15CA), and the official Guidance Note for Form 146 (earlier Form 15CB).

Disclaimer: This article is for professional information and general guidance only. Foreign-remittance taxability depends on the facts, the Income-tax Act, the applicable Rules, the relevant tax treaty, RBI/FEMA requirements and current administrative guidance. Specific transactions should be reviewed before implementation.