From 1 April 2026, the old Income‑tax Act, 1961 is replaced by the new Income‑tax Act, 2025. Along with this, the Income‑tax Rules, 2026 come into force and almost all familiar forms are renumbered. One of the most important changes for cross‑border payments is the renumbering of Form 15CA and Form 15CB into a new set of foreign remittance forms.
In simple terms, Form 15CB does not disappear, but it gets a new name and format. Under the new Rules, the remitter’s declaration will be filed in Form 145 (old Form 15CA) and the Chartered Accountant’s certificate will be filed in Form 146 (old Form 15CB). The substance remains very similar, but the references, rule numbers and e‑filing flow change.
This post explains the key Form 15CB changes from 1 April 2026 and what finance teams and CAs should watch out for.
1. Old framework: Form 15CA and Form 15CB under Rule 37BB
Under the earlier regime, any person making a payment to a non‑resident (not being a company) or to a foreign company had to consider the requirement to file:
- Form 15CA – an online declaration by the remitter; and
- Form 15CB – a certificate issued by a Chartered Accountant.
Form 15CB was required where:
- The remittance was chargeable to tax in India.
- The aggregate of such remittances of a similar nature to a non‑resident exceeded ₹5 lakh in a financial year.
- There was no specific lower or nil deduction order from the Assessing Officer.
Rule 37BB also contained a negative list of transactions where Form 15CA and Form 15CB were not required at all (for example, many import payments and certain personal remittances).
Over time, Form 15CB became a critical document. Banks started insisting on a CA certificate even in borderline situations, and Form 15CB changes became a common topic in tax discussions.
2. New regime from 1 April 2026: renumbering and new form names
With effect from 1 April 2026:
- The Income‑tax Act, 2025 applies to income earned in the new tax year 2026‑27.
- The Income‑tax Rules, 2026 consolidate and renumber old rules and forms.
- The foreign remittance forms are renumbered as follows:
- Old Form 15CA → New Form 145 (remitter’s information form).
- Old Form 15CB → New Form 146 (Chartered Accountant’s certificate).
- Old Form 15CC (AD bank reporting) → New Form 147.
So, when you talk about “Form 15CB changes from 1 April 2026”, you are essentially referring to the fact that:
- The form number,
- The rule reference, and
- The portal workflow
are updated, but the core concept of a CA‑certified tax analysis before remittance continues.
3. When is the new Form 146 (old 15CB) still required?
Even after renumbering, the triggers for obtaining a CA certificate remain almost identical to the old regime. In most practical situations, you still need Form 146 (earlier 15CB) if:
- The remittance is being made to a non‑resident or foreign company.
- The sum is chargeable to tax in India under the Income‑tax Act and/or the relevant Double Taxation Avoidance Agreement (DTAA).
- The aggregate of such remittances of that nature in the financial year exceeds the prescribed threshold (broadly at the ₹5 lakh level).
- You do not have a specific certificate/order from the Assessing Officer determining the rate or authorising nil deduction.
A negative list of exceptions is retained in the new Rules. These are categories of payments where neither the remitter declaration (Form 145) nor the CA certificate (Form 146) is required. Typical examples include certain import payments and specified routine transactions. The list is refined and updated, but conceptually similar to the earlier Rule 37BB list.
For day‑to‑day work, you can safely assume that any payment that needed Form 15CB earlier will now need Form 146, unless it falls in the updated exemption list.
4. What does the CA certify in the new form?
The new Form 146 continues to ask the Chartered Accountant to certify the key tax aspects of the remittance. The CA must still:
- Identify the payee’s details and confirm non‑resident status.
- Classify the exact nature of the income: interest, royalty, fees for technical services, capital gains, business income, commission, independent personal services, etc.
- Analyse whether the income is chargeable to tax in India under the new Act and the relevant DTAA article.
- Compare the rate under domestic law and the treaty and select the beneficial rate.
- Compute the amount chargeable to tax and the amount of tax to be deducted at source before remittance.
- Confirm that supporting documents like agreements, invoices, Tax Residency Certificate, Form 10F and other declarations have been examined where treaty benefits are claimed.
The structure and wording of the questions in the new Form 146 are more streamlined and aligned to the new Act, but any CA who was already issuing robust Form 15CB certificates will find the substantive work almost unchanged.
5. Transition cases: old year income, new year remittance
One area that can cause confusion is the treatment of transactions around the cut‑off date of 31 March 2026.
Consider this situation: services were rendered in February 2026 (FY 2025‑26, old Act), but the actual remittance is made in April 2026 (tax year 2026‑27, new Act).
Here, it is useful to separate two layers:
- Substantive law (taxability and rate)
- The taxability of the underlying income and the applicable rate of TDS are determined by the law that applied in the year of accrual. In this example, you still analyse taxability under the provisions of the old 1961 Act and the then‑applicable DTAA interpretation.
- Procedural law (which form to file)
- The procedural requirement at the time of remittance follows the law in force on the remittance date. For an April 2026 remittance, you will use New Form 145 and Form 146, even though your analysis refers to old‑Act sections.
For remittances already completed before 1 April 2026, existing Form 15CA and Form 15CB remain valid. There is no requirement to re‑file them in the new format as long as the remittance was made within the validity period mentioned in those forms.
6. Practical impact on CAs and finance teams
For semi‑technical readers like CFOs, finance controllers and CAs, the key Form 15CB changes from 1 April 2026 can be summarised as follows:
- Terminology change, not concept change
You will gradually stop seeing “Form 15CB” in the Rules and on the portal and start seeing “Form 146”. Internally, you may still call it “15CB certificate” for some time, but legally and on the portal it will be Form 146. - Same caution needed on tax analysis
The department will continue to rely heavily on CA‑certified remittance forms as a risk‑selection tool. Incorrect classification of income, wrong DTAA articles or casual “not taxable” positions can attract penalties and scrutiny just as before, if not more. - Update your SOPs, checklists and templates
All internal documents that refer to “Form 15CA/15CB” should be updated to “Form 145/146”. This includes client engagement letters, internal checklists, process notes, training materials and bank communication templates. - Portal and utility changes
Teams that use utilities, APIs or integrated software to generate or track Form 15CA/15CB will need to update those tools to handle new form numbers and schemas. Early testing in April 2026 is advisable.
7. Key takeaways
- Form 15CB changes from 1 April 2026 are primarily structural and procedural: new Act, new Rules, new form numbers.
- The new Form 146 is the functional successor of old Form 15CB. The situations in which you need a CA certificate and the information required remain largely the same.
- For remittances that relate to FY 2025‑26 but are paid after 1 April 2026, apply old‑law concepts for taxability but follow new‑law procedures for forms.
- CAs and finance teams should promptly update their SOPs and educate business stakeholders so that foreign remittances from April 2026 onwards are handled smoothly under the new framework.
