Form 145 and Form 146: frequently asked questions for NRIs and businesses

Last updated 3 August 2026

Full Answer

What is Form 145 and who needs to file it?

Form 145 is the online declaration a person making a foreign remittance files on the Income Tax portal before the payment goes out. It replaced Form 15CA effective 1 April 2026, under the Income Tax Act, 2025. Anyone remitting money outside India, whether an individual, an NRI, or a business, needs to file it, whether the payment is for services, an investment, a gift, or any other outward transfer that falls within its scope. The remitter is responsible for filing it themselves; it isn't something the bank or the CA files on your behalf.

What is Form 146 and who issues it?

Form 146 is the certificate a practicing Chartered Accountant issues after independently reviewing a foreign remittance for its tax treatment. It replaced Form 15CB from 1 April 2026. The CA examines the nature of the payment, determines whether tax needs to be withheld, checks whether a tax treaty (DTAA) applies, and certifies the position under their digital signature. Only a CA holding a valid Certificate of Practice from ICAI can issue it, and for remittances above the certification threshold, it's required before the corresponding Form 145 can be completed.

Do NRIs transferring money from NRO to NRE accounts need Form 145/146?

NRO to NRE transfers generally fall within the same scope that earlier required Form 15CA and, above the threshold, Form 15CB, so under the new regime, the same transfer needs Form 145 and, where applicable, Form 146. This is because the transfer moves funds from a non-repatriable account into a freely repatriable one, and the tax department wants the same visibility into the source of funds it had before. Whether Form 146 is also needed depends on the amount and the nature of the funds in the NRO account. NRIs making this transfer should expect their bank to ask for Form 145, and Form 146 where relevant, exactly as they asked for 15CA and 15CB earlier.

Is the ₹5 lakh threshold for CA certification still the same under Form 146?

Based on what has been confirmed so far, the shift from Form 15CB to Form 146 is a renumbering of the form and its legal basis under the Income Tax Act, 2025, rather than a rebuild of the underlying rule. The ₹5 lakh threshold that triggered mandatory CA certification is expected to continue in substance. Businesses and NRIs should keep treating remittances above this level as needing a CA certificate until the detailed Form 146 rules and any updated threshold are formally published. If you're close to the threshold or unsure, it's worth getting a quick CA opinion before you file.

Do businesses paying foreign vendors (e.g. software subscriptions) need Form 145/146?

Yes. An Indian business paying a foreign SaaS vendor, a cloud services provider, an overseas contractor, or any other foreign payment for goods or services needs to file Form 145 for that remittance, the same way it would have filed Form 15CA earlier. Where the payment is taxable in India and crosses the certification threshold, Form 146 is required as well, in place of the earlier Form 15CB. Recurring payments, such as monthly software subscriptions, don't get an exemption just because they repeat; each remittance is treated on its own terms by the bank. Businesses already used to the 15CA/15CB routine for vendor payments will find the process largely unchanged, just under the new form names.

What happens to remittances that started under Form 15CA/15CB before 1 April 2026?

Remittances where the Form 15CA and Form 15CB paperwork was already filed before 1 April 2026 keep that paperwork; there's no need to go back and refile them as Form 145 or Form 146. Any remittance that is new, or where the declaration or certificate hadn't yet been filed by the cutover date, goes through Form 145 and Form 146 instead. Beyond this general principle, detailed transition mechanics haven't been published, so if you have a remittance that falls right around the 1 April 2026 cutover, it's worth confirming with your CA or bank how that specific transaction should be handled.

Does the UDIN requirement still apply to Form 146?

Yes. Every certificate a CA issues, whether it was called Form 15CB or is now called Form 146, needs to carry a UDIN (Unique Document Identification Number) generated on the ICAI UDIN portal by the certifying CA. This requirement exists to prevent backdated or fraudulent certificates, and nothing about the change from 15CB to Form 146 removes it. You can still verify a Form 146 certificate's authenticity by checking its UDIN on the ICAI portal.

Can Shunya handle Form 145/146 filing entirely online?

Yes. Shunya's CA team reviews your remittance details, issues Form 146 where required, and files Form 145 on the Income Tax portal; the entire process is handled online without needing to visit a CA's office in person. This is the same online-first process Shunya already used for Form 15CA and Form 15CB, now updated for the new form names and legal references under the Income Tax Act, 2025. Whether you're an NRI moving personal funds or a business paying an overseas vendor, you can get your remittance documentation ready without an in-person visit.

This article is for general information only. For your specific remittance, consult a practicing CA.