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May 07, 2026
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Form 145 under New Income Tax Act, 2025: Complete Guide for Foreign Remittance Compliance in India (Replacing Form 15CA)

Foreign remittances from India are now entering a new compliance era under the Income Tax Act, 2025. One of the biggest changes introduced by the Income Tax Department is the launch of Form 145, which replaces the old Form 15CA mechanism for reporting payments made to non-residents and foreign entities.

This change directly impacts:

  • NRIs
  • Indian residents sending money abroad
  • Startups
  • Importers
  • Exporters
  • Freelancers
  • IT companies
  • SaaS businesses
  • Foreign consultants
  • Cross-border investors
  • Indian companies making overseas payments

If you are making foreign remittances from India in FY 2026-27 onwards, understanding Form 145, Form 146, TDS provisions, DTAA benefits, FEMA rules, and outward remittance procedures has become extremely important.

At Dinesh Aarjav & Associates, our international tax experts regularly assist clients across India, USA, Canada, UK, UAE, Singapore, and Australia with foreign remittance compliance, Form 145 filing, DTAA advisory, FEMA compliance, and NRI taxation matters.

What is Form 145 under Income Tax Act, 2025?

Form 145 is a mandatory reporting form prescribed under the new Income Tax Act, 2025 for certain payments made to non-residents or foreign companies outside India.

It replaces the earlier Form 15CA system applicable under the old Income Tax Act, 1961.

The form is required to be furnished before remitting money outside India in specified situations involving:

  • Taxable payments to non-residents
  • Cross-border service payments
  • Foreign consultancy fees
  • Royalty payments
  • Technical fees
  • Foreign investment transactions
  • Repatriation transactions
  • Overseas commission payments
  • Software and SaaS subscriptions
  • Import of services

Official User Manual:
Income Tax Department – Form 145 User Manual

Official Form Page:
Income Tax Department – Form 145

Form 145 Replaces Form 15CA from FY 2026-27

The government has rationalized and renumbered several forms under the Income Tax Act, 2025 framework.

Earlier System New System under Income Tax Act, 2025
Form 15CA Form 145
Form 15CB Form 146

This means taxpayers and professionals dealing with international transactions must now transition from the old 15CA/15CB mechanism to the new Form 145/Form 146 reporting structure.

Why Form 145 is Extremely Important in 2026

India is rapidly tightening scrutiny on:

  • Foreign remittances
  • Cross-border transactions
  • FEMA compliance
  • DTAA misuse
  • TDS deduction on overseas payments
  • International tax reporting
  • Global information exchange mechanisms

Banks and Authorized Dealers (AD Banks) are increasingly seeking proper documentation before processing outward remittances from India.

Improper compliance can lead to:

  • Delay in remittance
  • Bank rejection
  • Income tax notices
  • TDS default proceedings
  • FEMA complications
  • Penalties and interest

Hence proper filing of Form 145 has become critical.

Simplify Foreign Remittance Compliance

Get expert support for Form 145, Form 146, DTAA, and FEMA compliance to ensure smooth and hassle-free overseas payments from India.

Who Needs to File Form 145?

Form 145 may be required for:

Indian Businesses Making Overseas Payments

Examples include:

  • Foreign vendor payments
  • Import of services
  • Software subscriptions
  • Foreign marketing agencies
  • Overseas consultants
  • Royalty payments
  • Technical service fees

Startups and SaaS Companies

Indian startups frequently make payments for:

  • AWS
  • Google Cloud
  • Meta Ads
  • Foreign software subscriptions
  • Overseas freelancers
  • International consultants

These transactions may trigger Form 145 compliance.

NRIs and OCI Card Holders

NRIs often require Form 145 compliance in situations involving:

  • Repatriation of sale proceeds
  • Property sale transactions
  • Overseas remittances
  • Investment transfers
  • Inheritance remittances
  • NRO to NRE transfers

Residents Sending Money Abroad

Residents remitting funds outside India for taxable transactions may also require compliance depending on the nature of payment.

Different Parts of Form 145 Explained

Similar to old Form 15CA, the new Form 145 contains multiple sections based on taxability and remittance amount.

Part A of Form 145

Applicable where:

  • Remittance is taxable
  • Aggregate remittance does not exceed ₹5 lakh during the financial year

Generally, Form 146 certification may not be required.

Part B of Form 145

Applicable where:

  • Remittance exceeds ₹5 lakh
  • Lower or nil deduction certificate/order has been obtained from Income Tax Department

This may include cases involving lower withholding approvals.

Part C of Form 145

Applicable where:

  • Remittance exceeds ₹5 lakh
  • Payment is taxable in India
  • Chartered Accountant certificate in Form 146 is required

This is one of the most commonly used categories for businesses making foreign remittances.

Part D of Form 145

Applicable where:

  • Payment is not chargeable to tax in India

However, reporting obligations may still continue depending on the transaction type and banking requirements.

What is Form 146?

Form 146 is the Chartered Accountant certificate replacing old Form 15CB.

The CA certifies:

  • Nature of remittance
  • Taxability under Indian law
  • DTAA applicability
  • Withholding tax rate
  • Relevant TDS provisions
  • FEMA implications
  • Treaty eligibility
  • Supporting documentation

Banks rely heavily on Form 146 before permitting outward remittances.

Documents Required for Form 145 Filing

The following documents are generally required:

Basic Documents

  • PAN of remitter
  • Address proof
  • Bank details
  • Remittance details
  • Purpose code

Transaction Documents

  • Invoice
  • Agreement/contract
  • Service agreement
  • Purchase order

International Tax Documents

  • Tax Residency Certificate (TRC)
  • Form 10F
  • No PE declaration
  • DTAA documents
  • Lower withholding certificate (if applicable)

Form 145 for NRIs Selling Property in India

One of the most searched topics in 2026 is:

“Is Form 145 required for NRI property sale remittance?”

In many cases, yes.

NRIs repatriating sale proceeds outside India may require:

  • TDS compliance
  • FEMA compliance
  • Form 145 filing
  • Form 146 certification
  • Lower/Nil TDS certificate
  • Capital gains computation

This becomes especially important for NRIs residing in:

  • USA
  • Canada
  • UK
  • UAE
  • Singapore
  • Australia

Form 145 for USA, Canada, UK & UAE NRIs

Many overseas Indians search for:

  • Form 145 for NRI
  • Form 145 USA
  • Form 145 Canada
  • Form 145 UAE
  • Form 145 UK
  • How to remit money from India abroad
  • New Form 15CA replacement
  • TDS on remittance from India

The new framework significantly impacts global Indians dealing with Indian assets and overseas remittances.

Common Transactions Covered under Form 145

Foreign Consultancy Payments

Payments to:

  • US consultants
  • UK advisors
  • Canadian freelancers
  • UAE consultants

may require withholding tax analysis.

Import of Services

Common for:

  • IT companies
  • Digital businesses
  • Startups
  • Marketing agencies

SaaS & Software Payments

Payments to:

  • Adobe
  • Microsoft
  • Google
  • AWS
  • Zoom
  • Foreign SaaS companies

may attract remittance reporting obligations.

Royalty & Technical Service Fees

Cross-border royalty and FTS transactions are heavily scrutinized under Indian tax law and DTAA provisions.

DTAA Benefits and Form 145

India has Double Tax Avoidance Agreements (DTAAs) with multiple countries including:

  • USA
  • Canada
  • UK
  • UAE
  • Singapore
  • Australia

Taxpayers claiming treaty benefits must maintain:

  • TRC
  • Form 10F
  • Beneficial ownership declarations
  • Supporting agreements

Improper treaty claims can lead to rejection by banks or future scrutiny.

FEMA Compliance and Foreign Remittance Rules

Apart from Income Tax compliance, foreign remittances must also satisfy FEMA requirements.

Banks typically evaluate:

  • Purpose code
  • Source of funds
  • Tax compliance
  • RBI regulations
  • Supporting documentation

Improper structuring can create FEMA complications later.

How to File Form 145 Online?

The Income Tax Department allows:

Online Filing

Through Income Tax e-filing portal.

Offline Utility Filing

Taxpayers can also use the official offline utility.

Official Portal:

Income Tax e-Filing Portal

Offline Utility for Form 145

The offline utility is especially useful for:

  • CA firms
  • Companies making recurring remittances
  • Shared service centers
  • MNCs
  • High-volume remittance transactions

The utility allows users to:

  • Prepare forms offline
  • Validate details
  • Upload data later
  • Maintain bulk compliance records

Major Mistakes Taxpayers Make in Form 145 Compliance

Assuming Non-Taxable Means No Compliance

Even non-taxable remittances may require reporting.

Ignoring DTAA Documentation

Without proper documents, treaty benefits may get denied.

Wrong TDS Deduction

Incorrect withholding can lead to notices and penalties.

FEMA Non-Compliance

Income tax compliance alone is not sufficient.

Improper Remittance Structuring

Banks may reject outward remittances if documents are incomplete.

Penalty for Non-Compliance

Failure to properly comply may result in:

  • Penalty proceedings
  • Interest liability
  • TDS default
  • Remittance delays
  • FEMA scrutiny
  • Income tax notices

Hence professional review becomes highly advisable for cross-border transactions.

How Dinesh Aarjav & Associates Can Help

At Dinesh Aarjav & Associates, we actively assist clients globally with:

Foreign Remittance Advisory

  • Form 145 filing
  • Form 146 certification
  • FEMA advisory
  • RBI compliance

NRI Taxation Services

  • NRI property sale taxation
  • Capital gains tax planning
  • DTAA Consultancy
  • Repatriation support

International Taxation

  • India-USA taxation
  • India-Canada taxation
  • India-UK taxation
  • UAE tax advisory
  • Cross-border structuring

Lower/Nil TDS Certificates

  • Lower withholding applications
  • Tax optimization
  • International withholding review

With 25+ years of experience and clients across India, USA, Canada, UK, UAE, Singapore, and Australia, our team regularly handles complex international tax and FEMA matters.

Conclusion

Form 145 represents a major compliance shift under the new Income Tax Act, 2025. Businesses, NRIs, startups, investors, and professionals making foreign remittances must carefully evaluate:

  • Taxability
  • DTAA applicability
  • FEMA implications
  • TDS obligations
  • Reporting requirements

With increasing global transparency and regulatory scrutiny, proper foreign remittance compliance has become more important than ever.

For expert assistance regarding Form 145, Form 146, foreign remittances, DTAA benefits, FEMA advisory, or NRI taxation, connect with Dinesh Aarjav & Associates

Also Read: 

NRE Account Taxability in India: Latest ITAT Ruling on Foreign Remittances

Supreme Court Caps TDS on Foreign Remittances at 10% Under DTAA | Section 206AA Cannot Override Treaty Benefits

US Remittance Tax on Sending Money to India Reduced to 1%: Big Relief for NRIs

US to India Remittance Tax 2025: What NRIs Must Know About the 3.5% Levy Under Trump's Proposal

Frequently Asked Questions

Not necessarily. Applicability depends on taxability, remittance tax compliance requirements, the nature of remittance, amount, and transaction structure.

Yes. Form 145 replaces Form 15CA under the Income Tax Act, 2025 framework.

Yes. Form 146 replaces Form 15CB.

In many taxable remittances exceeding prescribed thresholds, Form 146 certification may be required.

Yes, especially in certain repatriation and property sale related remittances.

About the Author

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CA Shailendra Jain

Associate
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CA Shailendra Jain is an Associate at Dinesh Aarjav & Associates with over 15 years of experience in NRI taxation, cross-border tax advisory, transfer pricing, tax litigation, and direct tax matters. He advises NRIs and businesses on international tax compliance, cross-border transactions, and dispute resolution before tax authorities.