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Form 145 & 146 replaces Form 15 CA and CB – Service Imports
  • FEMA
  • 5 minute read

From April 1, 2026, Form 15CA is replaced by Form 145, changing how Indians send money abroad under new compliance rules. Here’s how Rs 5 lakh and Rs 10 lakh limits work, and what 20% TCS means for your overseas transfers.

Sending money overseas has become routine for many Indians – whether for education, travel, investment or family needs. But from April 1, 2026, the rules governing foreign remittances have changed significantly. The government has replaced the old Form 15CA with a new, fully digital Form 145, tightening compliance while simplifying smaller transactions.

If you are planning to remit money abroad, understanding these changes is critical. A mistake in form selection, purpose code or documentation could delay your transfer or lead to higher tax deductions.

The most important change is the replacement of Form 15CA with Form 145, a new declaration system for foreign remittances. The aim is to make the process more transparent, digital and trackable.

The new forms are designed to align more closely with RBI Purpose Codes and ensure that tax data is validated in real-time before a remittance is authorized by an Authorized Dealer (AD) bank.

1. Form 145: The Master Declaration

Replacing Form 15CA with Form 145 is the primary reporting document. It is now divided into four distinct parts based on the nature and value of the remittance:

  • Part A: For taxable remittances where the aggregate amount to a single recipient does not exceed ₹5 Lakh in a financial year.
  • Part B: For taxable remittances exceeding ₹5 Lakh where a certificate from the Assessing Officer (AO) has been obtained (under Section 395).
  • Part C: For taxable remittances exceeding ₹5 Lakh where a Chartered Accountant’s certificate (Form 146) is obtained.
  • Part D: For remittances that are not chargeable to tax under the Income Tax Act (excluding specific exempt categories like LRS payments).

What happens at Rs 10 lakh? Understanding 20 per cent TCS

  • A key highlight of the new rules is the Tax Collected at Source (TCS) provision.
  • If you remit more than Rs 10 lakh in a year, especially for investments such as shares or property abroad, a 20 per cent TCS will apply.

2. Form 146: The CA Certification

Replacing Form 15CB with Form 146 is the professional certification.

  • It is a tax determination certificate where a CA verifies the chargeability under Sections 5 and 9 of the Act and applies relevant DTAA (Tax Treaty) benefits.
  • It now features real-time UDIN validation and is “consumed” by the portal once linked to a Form 145 (Part C) filing.

Need help with Form 145 or foreign remittance compliance? Contact Us for expert FEMA and RBI guidance.

Critical Changes for FEMA Compliance

Feature Change Detail
RBI Integration Form 145 now uses a structured dropdown of 65+ nature-of-remittance categories mapped directly to RBI Purpose Codes.
New Threshold The ₹5 Lakh limit remains the “tipping point” for requiring a CA certificate (Form 146) or an AO order.
DTAA Reporting Claiming treaty benefits now requires Form 41 and a Tax Residency Certificate (TRC) to be updated in the system prior to filing Form 145/146.
Real-time API Banks now have enhanced API access to verify these forms instantly, reducing the “float time” for foreign transfers.

While the process is more digital, the penalties for misclassification remain steep. Ensuring that the “Nature of Payment” in Form 145 matches the “Purpose Code” reported to the bank is the single most important step in avoiding regulatory friction.

What should you do before sending money abroad?

Before initiating any foreign remittance, keep these points in mind:

  • Choose the correct purpose code
  • Arrange CA or AO certificate if the amount exceeds Rs 5 lakh
  • Factor in TCS if sending more than Rs 10 lakh
  • Use your bank’s digital platform for filing Form 145
  • Double-check all details to avoid delays

At Sriya Enterprise, we specialize in navigating these FEMA and applicable purpose code of RBI to keep your global operations compliant and efficient.

Frequently Asked Questions

Form 145 is the new declaration form introduced from April 1, 2026, replacing Form 15CA for reporting foreign remittances made outside India.

Form 146 replaces Form 15CB and acts as a Chartered Accountant certificate for taxable foreign remittances exceeding the prescribed threshold under Income Tax rules.

Form 146 is generally required when taxable foreign remittances exceed ₹5 lakh in a financial year and no Assessing Officer certificate is obtained.

If the total taxable remittance to a recipient does not exceed ₹5 lakh in a financial year, Form 145 Part A can generally be used without a CA certificate.

If remittances exceed ₹10 lakh in a financial year for specified transactions like overseas investments, a 20% Tax Collected at Source (TCS) may apply.

Conclusion

The introduction of Form 145 and Form 146 marks a major shift in India’s foreign remittance compliance framework. By replacing the earlier Forms 15CA and 15CB with a more digital, integrated, and RBI-aligned system, the government aims to improve transparency, streamline reporting, and strengthen tax and FEMA compliance.

While the process has become faster and more automated, the compliance responsibility on remitters has also increased. Selecting the correct RBI Purpose Code, understanding taxability, managing TCS implications, and ensuring accurate documentation are now critical steps before initiating any overseas payment.

For individuals, businesses, exporters, importers, and global investors, proactive compliance is the best way to avoid delays, penalties, and regulatory scrutiny. As cross-border transactions continue to grow, staying updated with these evolving FEMA and remittance regulations is essential for smooth and compliant international operations.

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