From the assessment year relevant to financial year 2026-27, outbound payments to non-residents are supported on the income-tax portal through Form 145 (undertaking) and Form 146 (chartered accountant certificate), which replace the earlier Form 15CA and Form 15CB framework under the Income-tax Act, 2025 and Rule 220 of the Income-tax Rules, 2026.
Remittances still require FEMA compliance through authorised dealer banks. AD banks typically verify Form 145 before allowing the transfer. Incorrect classification causes delays, withholding errors, or double taxation.
This article summarises when each part of Form 145 applies and when Form 146 is required.
Form 145 — parts overview
| Part | When used (summary) |
|---|---|
| Part A | Taxable remittance not exceeding ₹5 lakh in the tax year (subject to conditions on the portal) |
| Part B | Taxable remittance exceeding ₹5 lakh with certificate from the Assessing Officer under Section 395(1) |
| Part C | Taxable remittance exceeding ₹5 lakh where Form 146 from a chartered accountant is required |
| Part D | Non-taxable remittances and other cases specified in Rule 220 |
Form 146 — CA certificate
A chartered accountant certifies matters such as:
- Nature and purpose of the remittance.
- Whether the payment is chargeable to tax in India.
- Applicable rate of tax / TDS and benefit under an applicable tax treaty.
- Compliance with provisions relating to payments to non-residents.
Form 146 is filed before the relevant Part C of Form 145. UDIN is mandatory on the certificate.
Specified payments under Rule 220
Rule 220 lists categories where simplified compliance may apply (for example certain imports, LRS-related payments, and other notified purposes). The list should be verified on the date of each remittance — not every import or overseas payment automatically qualifies for Part D.
TDS and treaty planning
- Identify income character — royalty, FTS, dividend, interest, business income, or other.
- Apply the applicable domestic rate or treaty rate; obtain treaty documentation from the non-resident where relevant.
- Consider certificates for lower or nil deduction where legally available.
- Ensure TDS returns and certificates are filed for credit to the non-resident payee.
Practical documentation pack
- Invoice, agreement, and board / authorisation for remittance.
- FEMA purpose code and AD bank documentation (including Form A2 where applicable).
- Permanent establishment analysis for business-income payments.
- Prior Form 146 and assessment records for recurring payees.
General professional information only. Form 145, Form 146, Rule 220, and portal utilities are subject to notification and amendment; verify the position before each remittance.