Form 15CA and Form 15CB are now Form 145 and Form 146 under Rule 220 of the Income-tax Rules, 2026 (earlier Rule 37BB): Form 145 is the remitter's online declaration for a payment to a non-resident, and Form 146 is the CA's certificate on its taxability and TDS. A CA certificate is needed when the payment is chargeable to tax and exceeds ₹5 lakh in the tax year and you do not have an Assessing Officer's certificate. CorporateWalla's CA team checks the DTAA position, issues Form 146 with UDIN and files Form 145 before the bank releases the money.
Start with two questions: is the payment chargeable to tax in India, and does the amount remitted to the payee exceed ₹5 lakh in the tax year?
| Your case | Form 145 (earlier 15CA) | Form 146 (earlier 15CB) | Other document |
|---|---|---|---|
| Individual's remittance not needing RBI approval (e.g. LRS) | Not required | Not required | Bank's LRS form |
| Payment of a nature in the specified RBI purpose-code list | Not required | Not required | Purpose code to the bank |
| Remittance by an IFSC unit | Not required | Not required | — |
| Taxable, up to ₹5 lakh in the tax year | Part A | Not required | TDS challan if tax deducted |
| Taxable, above ₹5 lakh, AO certificate held | Part B | Not required | Certificate under Section 395(1) |
| Taxable, above ₹5 lakh, no AO certificate | Part C | Required | Form 41 and TRC for DTAA rate |
| Not chargeable to tax in India | Part D | Not required | Basis for non-taxability on file |
Source: Form No. 145 (earlier Form No. 15CA) FAQs and Form No. 146 guidance, Income Tax Department (incometaxindia.gov.in).
| Item | Income-tax Act, 2025 / Rules, 2026 | Earlier (1961 Act / 1962 Rules) |
|---|---|---|
| Remitter's declaration | Form 145 | Form 15CA |
| Accountant's certificate | Form 146 | Form 15CB |
| Rule | Rule 220 | Rule 37BB |
| TDS on payments to non-residents | Section 393 | Section 195 |
| Penalty on remitter (up to ₹1 lakh) | Section 462 | Section 271-I |
| Penalty on accountant (₹10,000 per certificate) | Section 463 | Section 271J |
Remittances made on or after 1 April 2026 use Form 145 and Form 146 on the e-filing portal.
| Payment | Key documents | Main tax question |
|---|---|---|
| Software subscription or SaaS | Invoice, terms of use, payee TRC and Form 41 | Royalty or business income under the DTAA |
| Consultancy or technical services | Agreement, invoice, TRC, Form 41, no-PE declaration | Fees for technical services and the make-available test |
| Import of goods | Invoice, bill of entry | Usually not taxable in India |
| Advertising on foreign platforms | Invoices, account statement | Business income without a PE in India |
| Interest or loan repayment | Loan agreement, interest working | DTAA interest article; principal is not income |
| NRI repatriating property sale proceeds | Sale deed, capital-gains computation, TDS certificate | Tax on the gain paid or deducted |
A Delhi private company pays a US-resident consultancy firm ₹12,00,000 for market-research services. The firm has no office or staff in India and provides a US tax residency certificate and Form 41.
Illustrative scenario. The DTAA conclusion depends on the agreement and facts; the CA records the basis in Form 146.
Form 145 and Form 146 have replaced Form 15CA and 15CB on the e-filing portal for remittances from 1 April 2026. Both are event-based, with no fixed due date, but must be filed before the remittance. For an NRI, the tax on the underlying income still goes in the return; see NRI ITR filing. To reduce the TDS itself, apply for a lower deduction certificate for NRIs. The foreign-exchange side of the payment is covered under FEMA compliance.
Pick the speed and depth that matches your need. Same quality, same CA team — only the timeline changes.
Timeline: 1–2 working days (indicative)
Timeline: Monthly (as remittances arise)
Timeline: Custom
Government fee — paid by you at actuals
No government fee is payable for filing Form 145 or Form 146 on the income-tax e-filing portal. Any TDS deducted on the remittance is tax, not a fee, and is paid through the TDS challan.
Every price above is a professional fee, excluding GST and government charges. 50% upfront, 50% on delivery.
Priced per remittance for a standard payment such as consultancy, software, advertising or an NRI's own funds with documents ready. Multiple invoices to the same payee in one remittance count as one. Complex cases, such as permanent-establishment questions, grossing up across several DTAAs, or a lower-deduction application, are quoted separately.
Invoice or agreement, payee details, purpose and amount; we confirm whether Form 145 is needed at all and which part applies.
Our CA checks whether the payment is chargeable in India, the section, the DTAA article and rate, and whether the payee's Form 41 and tax residency certificate are in place.
Where tax is due, the TDS amount is worked out (grossed up if you bear the tax) and deposited using your TAN.
You assign Form 145 Part C to our CA on the e-filing portal; the CA files Form 146 with UDIN and e-verifies it with DSC.
Form 145 is pre-filled from the Form 146 acknowledgement and e-verified by you with DSC or EVC; we share both acknowledgements for the bank.
Tell us your requirement, a CA will call you in 30 minutes.
We tell you whether the remittance needs no form, Part A, Part B, Part C or Part D, so you neither over-file nor get stopped by the bank.
Form 146 is issued by a practising CA after reviewing the agreement and DTAA, not as a blind signature on the invoice.
Rate, grossing up and DTAA benefit are worked out before the money leaves, which protects you from a demand for short deduction later.
With documents ready, Form 146 and Form 145 can usually be filed within one to two working days.
