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If you have sent money abroad from India in the last few years, you have probably heard of Form 15CA and Form 15CB. These two forms have been the gatekeepers of certain outward remittances, particularly when a business or individual in India sends money to a foreign company or non-resident.

From 1 April 2026, that familiar pair is being retired. The Income Tax Act, 2025 and the Income Tax Rules, 2026 have introduced Form 145 and Form 146 as their successors. If you deal with cross-border payments to non-residents, here is what the change means for you and why it matters more than a simple rebranding.

Why the forms were renumbered in the first place

India has moved from the Income Tax Act, 1961 to the Income Tax Act, 2025. Every section number, rule reference, and form number tied to the old Act had to be rebuilt under the new framework.

Under the old law, Forms 15CA and 15CB were governed by Section 195(6) of the 1961 Act, read with Rule 37BB. Under the new law, the corresponding provision sits in Section 397(3)(d) of the 2025 Act, and the procedural rules now live in Rule 220 of the Income Tax Rules, 2026. The forms had to follow suit.

So:

• Form 15CA → Form 145 (declaration by the remitter)
• Form 15CB → Form 146 (certificate by a Chartered Accountant)

The purpose has not changed. Before a taxable payment leaves India to a non-resident or a foreign company, the tax department still wants the same question answered: has the correct tax been deducted at source?

Form 145: the remitter’s declaration

Form 145 is filed by the person or business making a payment to a non-resident, before the money is sent. The authorised dealer bank will not process such a remittance without it. Think of it as a customs declaration, but for money instead of goods.

Form 145 retains the four-part structure of the old Form 15CA. Which part you file depends on the nature and size of the payment:

• Part A: When the remittance is taxable and the aggregate during the year does not exceed Rs. 5 lakh.
• Part B: When the remittance is taxable, exceeds Rs. 5 lakh, and you already have a certificate from the Assessing Officer under Section 395(1) or 395(2) of the new Act.
• Part C: When the remittance is taxable, exceeds Rs. 5 lakh, and you need a CA certificate. This is where Form 146 comes into the picture.
• Part D: When the remittance is not taxable under the Act and no withholding is required.

One important update: the list of remittances exempt from Form 145 filing, previously 28 categories under Rule 37BB, has been expanded to 33 categories under Rule 220(3). Five new import-related RBI purpose codes that were earlier grey areas have now been clarified as exempt.

Form 146: the Chartered Accountant’s certificate

When a remittance to a non-resident crosses the Rs. 5 lakh threshold and is taxable in India, the tax department does not simply trust the remitter’s self-assessment of TDS. It requires an independent Chartered Accountant to examine the transaction and certify the tax position.

That is the job of Form 146. The CA:

• Examines the nature of income being paid abroad
• Checks whether India has a Double Taxation Avoidance Agreement (DTAA) with the recipient’s country
• Applies either the treaty rate or the domestic rate, whichever is lower
• Issues the certificate along with a UDIN (Unique Document Identification Number) for authenticity

Form 146 is submitted online on the income tax e-filing portal. Once uploaded by the CA, the remitter can view it in their dashboard, accept it, and then e-verify the linked Form 145 using a Digital Signature Certificate or EVC.

What stays the same

For anyone worried that every past compliance lesson is now obsolete, the good news is that the substantive requirements are unchanged:

• Thresholds for triggering Form 146 are similar to what existed under the old Rule 37BB
• The four-part structure of the declaration form continues
• The filing is still fully online on the income tax portal
• Processing time remains roughly 2 to 4 days from documentation to bank remittance

What changes in practice

The new framework brings a few genuine improvements:

1. Better digital integration: Form 145 and 146 are designed to be more tightly linked on the portal, reducing the duplication remitters used to face.
2. UDIN built in: CA certification through Form 146 now carries UDIN by default, improving traceability.
3. Clearer exempt list: The expanded list of 33 exempt categories removes ambiguity around common import payments.
4. Structured validation: The new forms include better input checks, which should reduce rejections due to formatting errors.

Transitional rules you should not miss

The shift happens on 1 April 2026, and the transition rules matter:

• Forms 15CA and 15CB already filed for remittances made on or before 31 March 2026 remain valid, as long as the remittance actually takes place within the validity period mentioned in the form.
• If a remittance is delayed beyond that period, fresh forms must be filed, and from 1 April 2026 onwards those fresh filings must be on Form 145 and Form 146.
• For remittances with liability accruing before 1 April 2026 but paid after that date: the procedural form follows the new Act (Form 145/146), while the taxability and TDS rate continue to be governed by the 1961 Act.

This dual-law principle is worth highlighting to your CA if you have pending remittances straddling the changeover.

What this means for Fairexpay customers*

If you are sending money abroad from India to a non-resident or a foreign company, the forex partner handles execution, but the income tax compliance piece is your responsibility (or your CA’s). A few practical takeaways:

• For remittances planned for April 2026 or later, ask your CA to prepare Form 145 and Form 146 rather than the old forms.
• For taxable remittances above Rs. 5 lakh, engage your CA early. The 2 to 4 day window still applies, and delays on the tax side delay the transfer itself.
• Keep your invoices, contracts, agreements, and bank details ready. The documentation requirements for Form 145/146 mirror the old ones.
• If your remittance falls under an exempt RBI purpose code, check whether it is now in the expanded list of 33. You may avoid form filing altogether.

*Please note: Form 145 and Form 146 are not applicable to individuals remitting money abroad with Fairexpay under the Liberalised Remittance Scheme (LRS), such as for overseas education, travel, gifts, maintenance of close relatives, or investments under the USD 250,000 annual limit. These forms apply only when a business or individual in India makes a taxable payment to a non-resident or a foreign company.

The bottom line

The move from Form 15CA/15CB to Form 145/146 is not a disruption, it is a modernisation. Same obligation, new architecture, slightly better user experience. The senders who will feel the change least are those who stay informed, work with their CA ahead of time, and choose a remittance partner that understands both the forex and the tax side of cross-border payments.

At Fairexpay, we make sure the forex execution is seamless and transparent. Whether you are an individual sending money under LRS or a business making a payment to a foreign vendor, we help you transfer abroad with confidence.

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