Form 15CA and 15CB, renumbered Forms 145 and 146: foreign remittance compliance

What the forms do

When an Indian person pays a non-resident, the payer must consider whether tax has to be deducted. Section 393 of the Income-tax Act, 2025 replaces section 195 of the 1961 Act for this purpose. Form 15CA (now Form 145) is the payer's declaration of the payment and the tax deducted, and banks ask for it before processing most outward remittances.

Form 15CB (now Form 146) is a certificate from a chartered accountant on the nature of the payment, its taxability under Indian law and any tax treaty, and the rate and amount of tax deducted.

The four parts of Form 15CA

The structure carries over unchanged into Form 145. For Part C, the CA files Form 146 online first, and its acknowledgement number is quoted in Form 145. The CA's certificate must be obtained before the declaration, so build in time for the CA to review the agreement and documents.

Payments that need neither form

Rule 220(3), which replaces Rule 37BB, lists categories of remittances that are exempt from Form 145 and 146 altogether, such as certain imports of goods and travel payments. The list was expanded under the 2026 Rules to include more import-related RBI purpose codes. Check the RBI purpose code for the remittance against the current exempt list before filing. Banks rely on the purpose code to decide whether to ask for the forms.

When to file and the bank's role

Both forms must be completed before the money leaves India. Banks generally refuse to process a remittance that needs the forms until they see the acknowledgement. The TDS deducted must then be deposited by the due date and reported in the quarterly statement for non-resident payments, which is Form 144 under the 2026 Rules (old Form 27Q). For recurring payments to the same payee, each remittance needs its own declaration, though one CA engagement can cover a series of similar invoices.

Documents needed

Without PAN of the payee, tax may need to be deducted at a higher rate, although relaxations apply where prescribed documents are furnished. Keep copies of all documents on file, as the tax department can examine the basis for a Part D or treaty claim years later.

• Invoice or agreement with the non-resident
• Tax Residency Certificate and Form 10F (now Form 41) of the payee, for treaty claims
• No permanent establishment declaration from the payee, where relevant
• PAN of the payee, if available
• Lower or nil deduction order, for Part B
• Bank and remittance details including purpose code

Penalties and common mistakes

Under section 271-I of the 1961 Act, failure to furnish the information or furnishing inaccurate information attracted a penalty of ₹1 lakh. Check the corresponding provision under the 2025 Act. Separately, short deduction of tax makes the payer liable for the tax, interest and possible disallowance of the expense.

Typical mistakes include choosing Part D without analysing whether income is taxable, relying on a treaty without a TRC, splitting payments to stay under ₹5 lakh, and wrong purpose codes.

Step by step

1. 1Classify the payment

   Check the purpose code and whether it is in the exempt list.

2. 2Collect payee documents

   Obtain invoice, TRC, Form 10F/41 and PAN details.

3. 3Determine taxability

   Decide the applicable part of Form 145, with CA help for larger payments.

4. 4File Form 146 if needed

   The CA certifies and files Form 146 online for Part C.

5. 5File Form 145

   The remitter files the declaration on the e-filing portal.

6. 6Remit and deposit TDS

   Share the acknowledgement with the bank, remit, and deposit TDS on time.