Under the Direct Tax Code 2025 (DTC 2025), India's foreign remittance compliance framework is being renumbered. Old Form 15CA becomes the new Form 145, and old Form 15CB becomes the new Form 146. The underlying obligation — Indian remitters must report taxable foreign payments and obtain a Chartered Accountant certificate — remains unchanged. As of July 2026, the DTC 2025 is in the implementation phase and CAs should prepare for the transition.

• Form 15CA (payer's declaration) → Form 145 under DTC 2025
• Form 15CB (CA's certificate) → Form 146 under DTC 2025
• Threshold: payments exceeding ₹5 lakh in aggregate during the financial year still require Form 146/Form 15CB

What Are Form 15CA and Form 15CB?

Form 15CA is an online declaration filed by an Indian resident (or entity) making a remittance to a non-resident or foreign company. It confirms whether the payment is taxable in India and whether Tax Deducted at Source (TDS) has been correctly deducted. Form 15CB is the corresponding certificate issued by a practicing Chartered Accountant, certifying the nature of the remittance, applicable DTAA provisions, and the rate of TDS deducted.

Together, these two documents are submitted to the authorised dealer (bank) before funds are transferred abroad. They are governed under Section 195 and Rule 37BB of the Income Tax Act, 1961 — provisions that will be renumbered (but substantively retained) under the Direct Tax Code 2025.

Why Is the Renumbering Happening?

The Direct Tax Code 2025 consolidates and restructures India's entire income tax framework. The goal is to simplify the law, reduce redundancy, and present it in plain language. As a result, every section, schedule, and prescribed form gets a new number. The substantive compliance requirement for foreign remittances is preserved, but CAs and tax professionals must map old references to new ones to avoid errors in filings.

This is not a policy change — it is an administrative renumbering. However, during the transition window, both old and new form numbers may be referenced in client engagements, bank instructions, and department circulars. Having a clear reference table is essential.

Complete Renumbering Table: Form 15CA/15CB to Form 145/146

Old Form (ITA 1961)	New Form (DTC 2025)	Filed By	Purpose	When Required
Form 15CA – Part A	Form 145 – Part A	Remitter (Indian payer)	Declaration for remittances not chargeable to tax OR below ₹5 lakh threshold	Remittance not taxable / small value
Form 15CA – Part B	Form 145 – Part B	Remitter (Indian payer)	Declaration based on order/certificate from Assessing Officer	AO certificate obtained under old Sec 195(2)/(3)
Form 15CA – Part C	Form 145 – Part C	Remitter (Indian payer)	Declaration for taxable remittances exceeding ₹5 lakh; filed after Form 15CB/146	Taxable remittance above ₹5 lakh — most common scenario
Form 15CA – Part D	Form 145 – Part D	Remitter (Indian payer)	Declaration for remittances listed in Rule 37BB exempt list (32 specified categories)	Remittances of exempt nature (e.g., imports, travel, education)
Form 15CB	Form 146	Practicing CA	CA's certificate certifying nature, DTAA applicability, TDS rate, and amount	Taxable remittance above ₹5 lakh (before filing Part C of Form 145)

Key rule: Form 146 (old: Form 15CB) must always be obtained from the CA before the remitter uploads Form 145 – Part C (old: Form 15CA – Part C) on the income tax portal. The CA uploads Form 146 and generates an acknowledgement number, which the remitter then quotes in Form 145 – Part C.

Old Section Numbers vs New DTC 2025 References

Old Reference (ITA 1961)	New Reference (DTC 2025)	Subject
Section 195	Renumbered under DTC 2025	TDS on payments to non-residents
Rule 37BB	Corresponding DTC rule	Procedural rule governing Form 15CA/15CB (145/146)
Section 115A	Renumbered under DTC 2025	Tax on royalty/FTS for non-residents: rate 20% + surcharge + cess
Section 90 / 90A	Renumbered under DTC 2025	DTAA applicability and tax relief
Form 10F	No change announced as of July 2026	Self-declaration by non-resident for DTAA benefit

Note: As of July 2026, the Central Board of Direct Taxes (CBDT) is expected to issue a formal mapping circular for all renumbered forms and sections under DTC 2025. Until that circular is issued, practitioners should cross-reference both sets of numbers in their working papers.

What Changes for CAs Under Form 146?

The CA's responsibility under new Form 146 is substantively identical to Form 15CB. However, there are several procedural nuances CAs must prepare for during the transition:

• Digital Signature Certificate (DSC): Form 146 (like Form 15CB) must be digitally signed by the practicing CA using their own DSC. This is a personal DSC, not the firm's DSC.
• Portal Login: The CA must have an active login on the income tax portal under their CA credentials to upload Form 146.
• Acknowledgement Number: On successful upload of Form 146, the portal generates an acknowledgement number. This number is mandatory for the remitter to complete Form 145 – Part C.
• Sequence Matters: The CA must complete Form 146 first. The remitter cannot file Form 145 – Part C without the CA's acknowledgement number from Form 146.
• DTAA Rate vs. Section 115A Rate: If the remitter is claiming a DTAA benefit, the CA must verify and certify the applicable DTAA rate. If no DTAA benefit is claimed, the tax is deducted under (what is currently) Section 115A at 20% + surcharge + cess for royalty and fees for technical services (FTS). Do not apply the older 10%/15% rates.

DTAA Compliance Checklist Before Filing Form 145/146

When a foreign company wants to claim DTAA benefit on its India-sourced income, the following documents are mandatory before the CA can certify Form 146 or the remitter can file Form 145:

• Tax Residency Certificate (TRC) — issued by the tax authority of the foreign company's home country
• Form 10F — self-declaration by the non-resident (filed online on India's income tax portal)
• No Permanent Establishment (No PE) Declaration — written declaration that the foreign company does not have a PE in India
• PAN Card of the foreign company — required to create an income tax login in India; also needed if the foreign company has to file an ITR in India
• Income Tax Login — the foreign company must have an active income tax portal login in India
• DSC of the Authorised Signatory — if the foreign company is required to file an ITR in India (i.e., it has claimed DTAA benefit), it must file using a DSC of its foreign authorised signatory

Obtaining the DSC of a foreign signatory requires: email and phone OTP from the individual, video verification, address proof (e.g., driving licence), a photograph, and a copy of the passport. See our detailed guide on No PE Declaration for DTAA in India and PAN Card for Foreign Company in India.

When Must a Foreign Company File an ITR in India?

A foreign company receiving royalty or FTS from India has two options. If it does not claim a DTAA benefit, it pays tax under the equivalent of current Section 115A at 20% + surcharge + cess and is not required to file an ITR in India. However, if it claims a lower rate under a DTAA, it must file an ITR in India for that financial year. This makes the income tax login, PAN, and DSC of the foreign signatory mandatory.

For reference, selected DTAA rates on royalty and FTS applicable to India:

Country	DTAA Rate (Royalty/FTS)	Section 115A Rate (if no DTAA claim)
UAE	10%	20% + surcharge + cess
Sweden	10%	20% + surcharge + cess
Switzerland	10%	20% + surcharge + cess
Russia	10%	20% + surcharge + cess
China	10%	20% + surcharge + cess
South Korea	10%	20% + surcharge + cess
Italy	20%	20% + surcharge + cess
Denmark	20%	20% + surcharge + cess

For detailed guidance on specific country DTAAs, see our articles on UAE-India DTAA, Russia-India DTAA, China-India DTAA, and South Korea-India DTAA.

Common Mistakes CAs Must Avoid

• Filing Form 145 – Part C before Form 146: The remitter cannot generate the acknowledgement number without the CA first uploading Form 146. Always complete Form 146 first.
• Using wrong TDS rate: The applicable rate under Section 115A (DTC 2025 equivalent) is 20% + surcharge + cess. Older rates of 10% or 15% are no longer applicable under current law.
• Missing TRC or Form 10F for DTAA benefit: Banks and the income tax department will reject remittance filings if TRC or Form 10F is absent when a DTAA rate is claimed.
• Incorrect Part selection in Form 145: Selecting the wrong Part (A, B, C, or D) affects both the data fields and the remitter's compliance record. Match the remittance type carefully to the Part.
• Exempt category remittances filed under Part C: Remittances listed in the 32 specified exempt categories (e.g., imports for goods, travel) should be reported under Form 145 – Part D, not Part C.

How Taxocity Helps with Form 145/146 (Form 15CA/15CB)

Taxocity has been helping businesses navigate India's foreign remittance compliance for over three decades. From obtaining TRC and Form 10F documentation to preparing Form 146 (15CB) certificates and filing Form 145 (15CA), our team of real human experts handles end-to-end compliance with a 100% compliance guarantee.

Whether you are an Indian company making royalty payments to a foreign group entity, a startup paying for SaaS subscriptions to overseas vendors, or a CA seeking support for high-volume remittance filings, Taxocity's specialists are equipped to handle the transition from the old ITA 1961 form numbering to the new DTC 2025 framework seamlessly.

For further reading, explore our guides on TDS on SaaS payments to foreign companies and Form 15CA/15CB for Singapore royalty payments.

Key Takeaways

1. Form 15CA = Form 145 (payer's declaration under DTC 2025) — same four-Part structure (A, B, C, D) is retained.
2. Form 15CB = Form 146 (CA's certificate under DTC 2025) — same CA obligation, same DSC requirement.
3. The CA always files Form 146 first; the remitter uses the acknowledgement number to complete Form 145 – Part C.
4. Section 115A rate remains 20% + surcharge + cess for royalty and FTS where no DTAA benefit is claimed.
5. Claiming a DTAA rate mandates TRC + Form 10F + No PE Declaration + PAN + income tax login + DSC of the foreign signatory.
6. CBDT is expected to issue a formal transition circular; until then, maintain dual references (old and new numbers) in your working files.

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Need help filing Form 145/146 (old Form 15CA/15CB) or navigating the DTC 2025 transition?

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Disclaimer

This article is for general informational purposes only and does not constitute tax, legal, or professional advice. The renumbering of forms and sections under the Direct Tax Code 2025 is subject to final CBDT notifications and circulars. Please consult a qualified tax advisor or Chartered Accountant before making any compliance decisions related to foreign remittances or TDS on non-resident payments.