Form 146 for foreign remittances: Who needs a CA certificate, when it applies and how taxpayers can file it

The Income Tax Department has announced a nationwide exercise to examine overseas remittances flagged as potentially suspicious.

The move has also drawn attention to Form 15CB, the accountant’s certificate prescribed for certain remittances under the Income Tax Rules, 1962. Under the new tax framework, the corresponding certificate is Form 146 under the Income Tax Rules, 2026.

But what exactly is Form 146, when is it required, and how can taxpayers use it? Here are the details.

What is Form 146?

Form 146 is a Chartered Accountant’s certificate for certain taxable payments made to a Non-Resident Indian (NRI) or a foreign company. It helps determine whether the payment is taxable in India and how much TDS should be deducted before the money is sent abroad.

Form 146 is generally required when:

• The payment is taxable in India.
• The total payment exceeds ₹5 lakh during the tax year.
• The taxpayer has not obtained the required certificate from the Assessing Officer.

It is an event-based form, which means a separate Form 146 is required for every remittance that meets these conditions.

For remittances from 1 April 2026, Forms 145 and 146 under the new tax framework apply. It is a professional certification mechanism to establish the tax treatment and TDS liability of eligible taxable foreign remittances.

Who can file Form 146?

The taxpayer does not file Form 146 directly. Instead, the taxpayer assigns it to a Chartered Accountant registered on the e-filing portal.

• An active registration on the e-filing portal.
• A registered Digital Signature Certificate (DSC).
• The Form 146 assignment from the taxpayer.

The CA examines the payment, its taxability under Indian law, the applicability of a Double Taxation Avoidance Agreement (DTAA), and the TDS liability.

How does Form 146 filing work?

The process involves first assigning the form to a CA and then having the CA complete and verify it.

Step 1: Assign Form 146 to the CA

• Log in to the e-filing portal.
• Go to “Authorised Partners” and select “My Chartered Accountants (CA).”
• Click “Add CA” and enter the CA’s membership number.
• Select Form 146 under the forms applicable under the Income Tax Act, 2025.
• Submit the assignment.

Step 2: CA files the form

• Log in to the e-filing portal and select Form 146, the relevant tax year, and the submission mode.
• Enter the taxpayer’s PAN and open the form.
• Fill in the details of the remitter, recipient, remittance, bank details, taxability, DTAA, and TDS.
• Review the completed form and submit it through DSC-based e-verification.
• Once successfully submitted, an acknowledgement number and transaction ID are generated.

What does Form 146 cover?

The form has different sections covering:

• Remitter and recipient details
• Remittance and bank details
• Taxability under the Income Tax Act
• Taxability under the applicable DTAA
• TDS details
• Verification

The CA may need documents such as invoices, agreements or contracts, details of the remittance, and bank information. If DTAA benefits are claimed, documents such as the Tax Residency Certificate (TRC) may also be required.

What happens after Form 146 is filed?

After submission, taxpayers can view the filed Form 146 on the e-filing portal.

The acknowledgement number from Form 146 is used while filing Form 145, Part C, for the relevant remittance. Once Form 145, Part C is successfully filed, the corresponding Form 146 is marked as “Consumed”.

Each Form 146 can be used only once to file the corresponding Form 145.

Form 145 must be filed by the person making the foreign remittance before the payment is made. However, it is not required for certain exempt transactions, including eligible individual remittances under the RBI’s Liberalised Remittance Scheme.

Disclaimer: This is only for informational and educational purposes. Please consult a qualified expert for the latest laws and regulations.