By CA Surekha Ahuja
From 1 April 2026, every Indian company or individual making a payment to a non-resident must use Form 145 instead of Form 15CA, and every Chartered Accountant certifying such payments must issue Form 146 instead of Form 15CB. The numbers changed. The obligations didn't. But UDIN is now mandatory, the exempt categories list grew, and the filing sequence is stricter. Here is everything you need to know.
What replaced what — the full picture
Until 31 Mar 2026
Remitter declarationForm 15CA
CA certificateForm 15CB
Section195(6), Act 1961
RuleRule 37BB
Exempt categories28
UDIN on CA certNot mandatory
CA cert threshold₹5 lakh
From 1 Apr 2026 Form 145
ReplacesForm 15CA
Filed byIndian payer / remitter
SectionSec 397(3)(d), Act 2025
RuleRule 220
Filing basisPer transaction, before each remittance
Exempt categories33 (5 new added)
PartsA, B, C, D
From 1 Apr 2026 Form 146
ReplacesForm 15CB
Filed byChartered Accountant only
SectionSec 397(3)(d), Act 2025
RuleRule 220
When requiredTaxable remittance >₹5L, no AO cert
UDINNow mandatory on every Form 146
Can be withdrawn?Yes — within 7 days
How Form 145 and Form 146 work together — the mandatory sequence
For a taxable remittance above ₹5 lakh — this sequence is non-negotiable
Step 1
Non-residentFile Form 41 + TRC
Establishes DTAA eligibility. Generates ARN. Payer cannot apply treaty rate without this ARN.
Step 2
Indian payerAssign Form 146 to CA
Log in → My Account → Add CA → enter CA's membership number → assign Form 146.
Step 3
Chartered AccountantFile Form 146 with UDIN + DSC
CA certifies income nature, TDS rate, DTAA article. Generates acknowledgement number. UDIN is mandatory.
Step 4
Indian payerFile Form 145 Part C
Links Form 146 ARN. Declares remittance details and DTAA rate to tax department. e-Verify via DSC or EVC.
Step 5
Bank (AD)Process remittance
Bank requires Form 145 acknowledgement + Form 146 + A2 form + supporting docs. 1–3 working days.
Form 145 — the four parts explained
Form 146 — what the CA certifies and what's new
The biggest change from Form 15CB: UDIN is now mandatory on every Form 146. UDIN is an 18-digit alphanumeric number generated on the ICAI portal that makes every CA certificate tamper-proof and verifiable in real time. A Form 146 without a valid UDIN is considered invalid — the remitter cannot use it to file Form 145 Part C, and the bank will not process the remittance. CAs must generate the UDIN on the ICAI portal before or at the time of filing.
Form 146 also now requires the CA's PAN and firm registration number. Once a Form 146 is used by the remitter in Part C of Form 145, it is marked "consumed" and cannot be reused. It can be withdrawn within 7 days if filed in error — but withdrawal automatically updates the linked Form 145 Part C status to "Withdrawn."
Form 146 also now requires the CA's PAN and firm registration number. Once a Form 146 is used by the remitter in Part C of Form 145, it is marked "consumed" and cannot be reused. It can be withdrawn within 7 days if filed in error — but withdrawal automatically updates the linked Form 145 Part C status to "Withdrawn."
Step-by-step filing procedure
Filing Form 145 — Parts A, B, D (no CA certificate)
Step 1
Log in
PAN + password at incometax.gov.in
Step 2
Navigate to form
e-File → Income Tax Forms → File Income Tax Forms → Act 2025 tab → Form 145
Step 3
Select Part
Choose A, B, or D based on taxability and amount. Fill remitter, remittee, amount, purpose, TDS details.
Step 4
Preview, e-Verify, submit
DSC or EVC. Download acknowledgement. Submit to bank with A2 form.
Filing Form 145 Part C — with CA certificate (Form 146)
Step 1 — Indian payer
Assign Form 146 to CA
My Account → Add CA → enter membership number → assign Form 146 to the transaction
Step 2 — CA
File Form 146 with UDIN
CA logs in → generates UDIN on ICAI portal → files Form 146 with DSC → provides acknowledgement number to remitter
Step 3 — Indian payer
File Form 145 Part C
Enter Form 146 acknowledgement number → fill remittance details → preview → e-Verify (DSC or EVC) → submit → give acknowledgement to bank
Exempt remittances — when Form 145 is not needed
Rule 220(3) lists 33 categories of exempt remittances — up from 28 under the old Rule 37BB. Five new import-related RBI purpose codes have been added that were previously grey areas. Common examples of typically exempt remittances include: payment for imports of goods, travel expenses, education remittances, medical treatment abroad, maintenance of close relatives, and subscription fees for international publications. Always verify the current Rule 220(3) list before assuming an exemption applies — assumptions can be costly.
Transition rule — old forms already filed
Form 15CA/15CB filed before 31 March 2026 remain valid provided the actual remittance occurred on or before the date specified in those forms. If the remittance was not completed within that window, fresh Form 145 and Form 146 must be filed.
Accrual in old year, remittance in new year: If income accrued in February 2026 but remittance happens in April 2026 — the reporting format follows the law in force on the date of remittance (Form 145/146 under Act 2025). But the taxability and rate are governed by the Act applicable to the year of accrual (Act 1961). Two different Acts applying to one transaction — confirm with your CA before processing.
Accrual in old year, remittance in new year: If income accrued in February 2026 but remittance happens in April 2026 — the reporting format follows the law in force on the date of remittance (Form 145/146 under Act 2025). But the taxability and rate are governed by the Act applicable to the year of accrual (Act 1961). Two different Acts applying to one transaction — confirm with your CA before processing.
Decision table — which form do you need?
| Situation | Form required | Filed by | Timing |
|---|---|---|---|
| Taxable remittance ≤₹5L in the year | Form 145 Part A | Indian payer | Before each remittance |
| Taxable remittance >₹5L — AO rate certificate obtained | Form 145 Part B | Indian payer | Before each remittance · attach Form 128 |
| Taxable remittance >₹5L — no AO certificate | Form 146 first then Form 145 Part C | CA files 146 · payer files 145 | CA files 146 → payer uses ARN in Part C → before remittance |
| Remittance not taxable in India | Form 145 Part D | Indian payer | Before each remittance |
| Remittance falls under Rule 220(3) exempt list | No form needed | — | Verify exemption applies first |
| Non-resident wants DTAA lower rate | Form 41 + TRC — non-resident files annually | Non-resident | Once per tax year · before ARN is shared with payer |
Penalties for non-compliance
| Default | Liable party | Consequence | Severity |
|---|---|---|---|
| Form 145 not filed before remittance | Indian payer | Penalty up to ₹1 lakh under Section 462. Bank will refuse to process remittance — transaction blocked. | Critical |
| Inaccurate information in Form 145 | Indian payer | Penalty up to ₹1 lakh under Section 462 | Critical |
| Form 146 filed without UDIN | CA | Certificate considered invalid. Form 145 Part C cannot proceed. Remittance blocked. | Critical |
| Incorrect information in Form 146 | CA | Penalty up to ₹10,000 per certificate | High |
| TDS not deducted or short deducted | Indian payer | Assessee-in-default. 1% per month interest + penalty equal to TDS amount + 100% expense disallowance | Critical |
| Form 145 and Form 146 data mismatch | Indian payer | Selected for AO verification. Risk of demand, interest, and scrutiny. | High |
Common errors — click to expand fix
CriticalWarningCompliance
Pre-filing checklist for Indian payers
Non-resident has filed Form 41 and shared ARN — confirm before any payment
Determined correct Part (A / B / C / D) based on taxability and amount
Verified payment is not in the Rule 220(3) exempt list before assuming no form needed
For Part C: CA assigned on portal and Form 146 filed with valid UDIN before starting Form 145
Form 146 acknowledgement number in hand before opening Part C
Remittance amount, date, and DTAA article consistent between Form 145 and Form 146
Form 145 e-verified via DSC or EVC — acknowledgement downloaded
Full documentation package ready for bank: Form 145 + Form 146 + A2 + invoice + TDS challan
TDS deducted at correct rate — DTAA rate only if Form 41 ARN received from non-resident
All records retained for 7 years for potential AO scrutiny
