Form 15CA/15CB to Form 145/146: Foreign Remittance Transition Guide

Foreign remittance compliance has always required careful form selection — the right form depends on the nature of the payment, whether it is taxable, what withholding applies, and what the applicable law says about certification. With the Income-tax Act, 2025 now in effect, the form references for remittance-related compliance are shifting. Form 15CA and Form 15CB, familiar from the Income Tax Act, 1961 framework, correspond to Form 145 and Form 146 in the new structure. Treating these labels as interchangeable without checking the applicable period is the kind of error that creates problems at the bank and with the department.

This guide is written for taxpayers, founders, finance teams, and filers working through the transition. It is an educational readiness note, not professional advice on any individual remittance. Always verify against the notified forms, the official portal, and your own documents for each transaction.

What changed

The nature of remittance compliance has not changed — a payment that is chargeable to tax in India still requires withholding, and the remitter must still produce evidence of that compliance before the bank processes the transfer. What has changed is which form applies, and that depends on the date and the law governing the transaction.

A remittance processed under the Income Tax Act, 1961 framework references Form 15CA and Form 15CB. A remittance processed under the Income-tax Act, 2025 framework references Form 145 and Form 146. When both old-period corrections and new-period transactions appear in the same month — which is common during transition — the file must be clearly tagged so each document references the correct form and law.

Why it matters now

The transition period creates a genuine administrative complication. AY 2026-27 return work (covering FY 2025-26 under the old Act), Tax Year 2026-27 compliance (under the new Act), unresolved old notices, and new-format forms can all land on the desk simultaneously. A remittance team or finance manager who does not distinguish between these periods risks raising the wrong form, presenting the bank with mismatched documents, or creating a TDS position that does not hold up to scrutiny.

A well-organised file for any remittance should state: the transaction date, the law governing that date, the applicable form reference, the taxability position, the withholding basis, and the supporting documents. If the CA certificate covers the transaction, the certificate should reference the same period and form as the portal submission and the bank advice.

Practical example

A royalty remittance planned after 1 April 2026 falls under the Income-tax Act, 2025 period, so the form check should reference Form 145 and Form 146. An old-period correction — say, a revised TDS position for a remittance made in FY 2025-26 — still involves Form 15CA and Form 15CB documentation and the earlier law's requirements. Mixing these up in the same transaction folder is a specific risk to watch for.

Records to keep

• Invoice and the underlying commercial agreement for the transaction
• Tax residency certificate of the non-resident recipient, where applicable
• CA certificate record (Form 15CB or Form 146 depending on the period) and portal acknowledgement
• Bank remittance proof and purpose code confirmation

Step-by-step checklist

• Identify whether the foreign remittance form selection affects AY 2026-27 filing, Tax Year 2026-27 compliance, or both, and tag accordingly.
• Read the official source for the relevant period and map the correct form to your transaction type, taxpayer category, and remittance date.
• Collect source records, computation notes, challans, statements, and declarations before the payment is initiated.
• Check whether the selected form and taxability position affect the ITR filing, any schedules, TDS/TCS obligations, or a wider disclosure requirement.
• Preserve the return or form acknowledgement, e-verification proof, bank advice, and all supporting working papers together.

Official sources

Common mistakes to avoid

• Referencing Form 15CA or Form 15CB for a remittance that falls under the new Income-tax Act, 2025 period without checking the applicable form.
• Mixing AY 2026-27 filing records with Tax Year 2026-27 payment or TDS records in the same compliance folder without period tags.
• Treating headline slab rates, rebate thresholds, or DTAA article numbers as a substitute for the actual taxability computation.
• Initiating the bank transfer before reconciling the TDS position, CA certificate, Form 26AS credits, and the portal acknowledgement.
• Not preserving the official source reference alongside the computation note that was used to select the form and determine taxability.

How MyeCA helps

MyeCA helps taxpayers and businesses organise foreign remittance records, compare the applicable form for the relevant period, prepare document checklists, review TDS and taxability positions, and facilitate CA coordination where Form 145 or Form 146 certificate work is required. When the facts are complex — multi-year arrangements, DTAA benefit claims, large payments to non-residents — a CA-led review before the remittance is processed is worth the time.

Final checklist

Confirm the remittance date and the applicable law. Identify the correct form — Form 145 and Form 146 for new-period transactions, Form 15CA and Form 15CB for old-period matters still being processed. Collect invoice, agreement, taxability note, and CA certificate. Submit through the portal, obtain the acknowledgement, and keep the bank proof, the portal record, and the supporting documents together in one clearly labelled folder.