Form 15CA and Form 15CB: Applicability, Filing and Foreign Remittance Compliance

Form 15CA and 15CB are important income-tax compliance documents for certain payments or remittances made by a person in India to a non-resident or foreign company. These forms help report the nature of the payment, applicable tax deduction and other relevant details before making a taxable remittance outside India.

The requirement depends on the nature of the remittance, whether the payment is chargeable to tax in India, the applicable provisions of the Income-tax Act and, where relevant, the provisions of a tax treaty. Form 15CA is generally furnished electronically by the remitter, while Form 15CB is a certificate issued by a Chartered Accountant in situations where certification is required.

Understanding when Form 15CA is required, when Form 15CB is necessary, what information is required and how the forms are filed can help avoid errors and delays in processing foreign remittances.

What are Form 15CA and Form 15CB?

Under the earlier Income Tax Act, Form 15CA was the declaration furnished by the person responsible for making a payment to a non-resident or foreign company. It provided information about the remitter, recipient, nature and amount of the remittance and applicable tax details.

Form 15CB was a certificate prepared by a Chartered Accountant where the prescribed conditions were satisfied. The CA examined the taxability of the remittance, including applicable provisions of the Income Tax Act and relevant DTAA provisions, and certified the relevant tax details.

For current remittances, the corresponding forms are:

The Income Tax Department confirms that Forms 145 and 146 are the corresponding forms under the new framework.

What changed from 1 April 2026?

The Income Tax Act, 1961 was repealed with effect from 1 April 2026, and the Income Tax Act, 2025 became applicable for the new tax framework. The Income Tax Department has accordingly introduced new forms under the Income Tax Rules, 2026.

For foreign remittances:

• Form 145 replaces Form 15CA.
• Form 146 replaces Form 15CB.
• The broad compliance mechanism remains similar.
• The ₹5 lakh threshold has been retained under the new rules.
• Form 145 continues to have Parts A, B, C and D.
• Form 146 is the CA certificate corresponding to the earlier Form 15CB.

Forms 15CA/15CB submitted for remittances made on or before 31 March 2026 remain valid subject to the conditions stated by the Income Tax Department. For remittances on or after 1 April 2026, the new Forms 145 and 146 should be used.

When is Form 15CA or its current equivalent Form 145 required?

The reporting requirement depends primarily on whether the remittance is taxable in India, the amount involved and whether an Assessing Officer’s certificate or CA certificate applies.

Under the current framework, Form 145 has four parts:

The Income Tax Department specifically confirms this four-part structure for Form 145.

For historical transactions governed by the Income Tax Act, 1961, the corresponding Form 15CA structure similarly contained Parts A, B, C and D.

When is Form 15CB required?

Form 15CB was not required for every foreign remittance.

Under the earlier framework, a CA certificate in Form 15CB was required where:

1. The payment or aggregate of payments to the non-resident exceeded ₹5 lakh during the financial year;
2. The payment was chargeable to income tax; and
3. The prescribed Assessing Officer certificate/order was not obtained.

The Income Tax Department describes Form 15CB as a tax-determination certificate, under which the CA examines the taxability of the remittance and applicable provisions, including DTAA where relevant.

For current remittances, the corresponding CA certificate is Form 146.

Form 15CA vs Form 15CB

A common misconception is that every foreign payment automatically requires both forms. That is not correct. The appropriate form and part depend on the taxability of the payment, amount, available certificates and the specific rules applicable to the remittance.

What types of payments may require foreign remittance tax compliance?

The tax treatment must be determined from the actual nature of the payment rather than merely from the fact that money is being sent abroad.

Examples can include:

• Professional or consultancy fees
• Technical service fees
• Royalty payments
• Interest
• Commission or other business payments
• Certain contractual payments
• Payments for services received from overseas vendors
• Other amounts potentially taxable in India under applicable provisions

The key question is whether the amount is chargeable to tax in India and, where applicable, whether a DTAA changes the tax outcome.

A payment being made to a foreign recipient does not by itself establish that TDS is payable. The underlying transaction and applicable tax provisions need to be examined.

How is taxability of a foreign remittance determined?

Before filing the applicable form, the remitter should establish the tax position of the payment.

The analysis may involve:

1. Nature of the payment

The agreement, invoice, purchase order or other supporting document should be examined to determine what the payment actually represents.

2. Domestic tax provisions

The payment should be examined under the applicable provisions governing income chargeable to tax in India.

3. DTAA

Where the recipient is located in a country with which India has a tax treaty, the relevant DTAA may affect taxation.

4. Recipient’s tax documents

Depending on the case, documents such as a Tax Residency Certificate (TRC) and prescribed supporting information may be relevant when treaty relief is being considered.

5. TDS requirement

Where the payment is chargeable to tax, the applicable withholding provisions and rate need to be determined before remittance.

This analysis is particularly important for payments involving technical services, royalty, interest, software, professional services and other cross-border transactions where classification can affect the tax treatment.

What documents are generally required?

The exact document list depends on the transaction. Commonly required documents may include:

• PAN of the remitter
• PAN or tax identification details of the recipient, where applicable
• Invoice from the foreign recipient
• Agreement or contract
• Description and purpose of the remittance
• Amount and currency of payment
• Proposed date of remittance
• Recipient’s name, address and country
• Bank/remittance details
• Tax Residency Certificate, where treaty relief is relevant
• Form 10F or other prescribed treaty documentation, where applicable
• Details of TDS deducted or payable
• Assessing Officer certificate/order, where applicable
• CA certificate where the applicable part requires it

The documents should support the actual tax position rather than being collected merely as a filing formality.

How does the Form 15CA/15CB filing process work?

For historical remittances governed by the earlier framework, the general process was:

1. Identify the nature of the payment.
2. Determine whether the payment is taxable in India.
3. Check the amount and applicable Form 15CA part.
4. Review DTAA provisions, if applicable.
5. Determine the applicable TDS rate.
6. Obtain Form 15CB from a CA where required.
7. File the applicable Form 15CA.
8. Complete the bank’s foreign-remittance formalities.
9. Maintain the supporting documents and filing acknowledgement.

For current remittances, the corresponding process uses Form 145 and, where required, Form 146.

The Income Tax Department’s current Form 145 procedure allows online and offline submission. For Part C, the taxpayer assigns the form to a CA, who submits Form 146; the taxpayer can then use the acknowledgement details to complete Part C of Form 145.

Is Form 15CB mandatory for every foreign remittance?

No.

Form 15CB was an event-based CA certificate and was not required for every remittance. Under the earlier rules, it was generally relevant where the taxable remittance or aggregate taxable remittances exceeded ₹5 lakh in the financial year and the prescribed Assessing Officer certificate was not obtained.

Under the current framework, Form 146 performs the corresponding CA certification function.

This is why determining the taxability and applicable reporting category before initiating the remittance is important.

What is the role of a Chartered Accountant?

A CA may be required to analyse and certify the tax position of a foreign remittance where the prescribed conditions apply.

The review can include:

• Nature of the payment
• Residential status of the recipient
• Domestic taxability
• Applicable TDS provisions
• DTAA applicability
• Treaty documentation
• Grossing-up, where relevant
• Amount of tax deductible
• Appropriate reporting form
• Supporting documentation

For current remittances requiring the CA certificate, the CA uses Form 146 and submits it through the Income Tax e-Filing system.

Important distinction: Form 15CA/15CB and LRS

Form 15CA/15CB should not be confused with the Liberalised Remittance Scheme (LRS).

LRS is an RBI foreign-exchange framework for resident individuals, whereas Form 15CA/15CB and their current equivalents concern income-tax reporting and tax determination for specified payments to non-residents.

The RBI states that the LRS limit for resident individuals is USD 250,000 per financial year for permitted transactions. The scheme is not available to companies, partnership firms, HUFs, trusts and similar non-individual entities.

Therefore, simply checking the LRS limit does not determine whether an income-tax remittance form or TDS compliance is required.

Common mistakes in foreign remittance compliance

Businesses and individuals should avoid the following mistakes:

• Assuming every foreign payment is tax-free.
• Assuming every foreign payment requires a CA certificate.
• Applying a DTAA rate without checking treaty conditions.
• Ignoring the nature of the underlying service or payment.
• Filing the form after the remittance instead of completing the required compliance beforehand.
• Using the wrong form after the 2026 transition.
• Treating RBI/LRS requirements as equivalent to income-tax requirements.
• Failing to retain invoices, agreements and tax documentation.
• Applying a TDS rate without reviewing the relevant tax provisions.
• Not checking whether multiple payments need to be considered together for the applicable threshold.

Form 15CA and 15CB after 1 April 2026: what should taxpayers use?

This is one of the most important updates for anyone searching for Form 15CA and Form 15CB today.

For remittances made on or after 1 April 2026, taxpayers should use the forms prescribed under the Income Tax Act, 2025:

• Form 145 — corresponding to Form 15CA
• Form 146 — corresponding to Form 15CB

The Income Tax Department has made these forms available on the e-Filing portal and has also published a mapping guide explaining the transition from the 1961 Act forms to the 2025 Act forms.

For historical searches and transactions, the terms “Form 15CA” and “Form 15CB” remain highly relevant because these were the forms used under the earlier framework.

Why professional review can be useful

Foreign remittances can involve several overlapping considerations: taxability, TDS, DTAA, documentation, income-tax reporting and bank requirements.

A professional review can help determine:

• Which form applies.
• Whether a CA certificate is required.
• Whether the payment is taxable in India.
• Which TDS provisions apply.
• Whether treaty relief can be considered.
• Which supporting documents should be maintained.
• Whether the remittance falls under an exemption from the applicable reporting requirement.

This is particularly useful for businesses making recurring payments to overseas vendors, consultants, technology providers, licensors or other non-resident parties.

FAQs

1. What is Form 15CA?

Form 15CA was the declaration used to furnish information about specified payments made to non-residents or foreign companies. For remittances made from 1 April 2026, the corresponding form under the Income Tax Act, 2025 is Form 145.

2. What is Form 15CB?

Form 15CB was a Chartered Accountant’s certificate used for specified taxable foreign remittances exceeding ₹5 lakh where the prescribed conditions for obtaining a CA certificate were met. Its current equivalent is Form 146.

3. Is Form 15CB mandatory for every foreign remittance?

No. Form 15CB was required only in specified circumstances. In particular, the earlier framework required it for taxable payments exceeding ₹5 lakh in the financial year where the prescribed Assessing Officer certificate had not been obtained.

4. What is the ₹5 lakh limit for Form 15CA/15CB?

Under the earlier framework, ₹5 lakh was relevant for determining the applicable part of Form 15CA and whether Form 15CB was required for specified taxable remittances. The Income Tax Department states that the new framework retains a similar threshold under the Income Tax Rules, 2026.

5. What replaced Form 15CA and Form 15CB?

For remittances made on or after 1 April 2026, Form 145 replaces Form 15CA and Form 146 replaces Form 15CB under the Income Tax Act, 2025.

6. Does every foreign remittance require Form 15CA or Form 145?

No. The reporting requirement depends on the applicable tax and foreign-remittance rules. Under the earlier Rule 37BB framework, specified exemptions existed, including certain individual remittances that did not require prior RBI approval and specified transactions under relevant RBI purpose codes.

7. When should the applicable foreign-remittance form be filed?

The Income Tax Department states that the relevant information form should be furnished before the remittance is made. Current Form 145 can be submitted through the Income Tax e-Filing portal or the prescribed offline utility.

8. Can a DTAA reduce the tax applicable to a foreign payment?

Potentially, yes. Where the recipient qualifies for treaty benefits and the relevant conditions are satisfied, the applicable DTAA may affect the tax treatment. The specific treaty provisions and supporting documentation should be reviewed before applying a treaty rate.

If you are making a payment to a non-resident and are unsure whether Form 15CA, Form 15CB, Form 145 or Form 146 applies, NBA Office can help review the nature of the remittance, applicable tax provisions, DTAA considerations, TDS requirements and required documentation before the payment is processed.

Contact NBA Office for professional assistance with foreign-remittance tax compliance and CA certification requirements.