From 1 April 2026, businesses making payments to non-residents need to work with the new Form 145 and Form 146 framework under the Income-tax Act, 2025. Form 145 replaces the earlier Form 15CA, while Form 146 corresponds to the earlier Form 15CB accountant’s certificate. The Income Tax Department has enabled both forms on the e-Filing portal and also provides a common offline utility.

For taxable remittances exceeding ₹5 lakh during the tax year, where the prescribed certificate from the Assessing Officer has not been obtained, Form 145 Part C operates with Form 146. The CA first submits Form 146 covering the remittance, domestic-law taxability, DTAA position and TDS details. The acknowledgement generated from Form 146 is then used by the remitter to proceed with Form 145 Part C, where relevant information is pre-filled from the CA certificate.

Business impact

For companies with regular overseas payments—consultancy, technical services, royalties, software, professional services or other cross-border expenditure—the change deserves attention in the payment approval workflow, not merely at the final banking stage.

Finance teams should ensure that agreements, invoices, nature of remittance, domestic tax analysis, DTAA position and withholding treatment are reviewed before payment is released.

Mardia Global | Tax & Business Insights for India