Form 146: the accountant certificate that replaces Form 15CB for taxable payments to non-residents

If you pay a non-resident or a foreign company and the payment is taxable in India, a chartered accountant may now have to sign off on it in Form 146. Under the Income-tax Act, 2025, Form 146 is the accountant's certificate that replaces the old Form 15CB. The Income Tax Department's Form 146 user manual says it plainly: "As per the Income tax Act 1961, Form 146 is known as Form 15CB." The certificate is needed once a taxable payment, or the total of such payments, goes above Rs 5,00,000 in a tax year, and it is needed "every time you make such a payment".

This guide covers what Form 146 certifies, its seven panels, how it feeds into Part C of Form 145 (which replaced Form 15CA), and the 26-step filing process the manual sets out for chartered accountants. If you are new to these forms, our glossary entry on Form 15CA and 15CB explains the older versions. Our earlier guide to Form 145, the pre-remittance filing, covers the remitter's side.

What the Section Says

The manual defines Form 146 in one sentence. It is "an Accountant's certificate required for payment to be made to a Non-Resident (not being a Company) or to a Foreign Company, which is taxable and if the payment / aggregate of such payments exceeds Rs 5 Lakh in the tax year". In the manual's plainer words, it is "a certificate in which a CA checks and confirms the tax responsibility for sending money abroad".

Three conditions must all be met before Form 146 is needed:

Once all three are met, the remitter has two routes under Form 145. Part B uses a certificate from the Assessing Officer under Section 395(1) or 395(2) of the Income-tax Act, 2025. Part C uses the accountant's certificate in Form 146. The "accountant" who may sign it is defined in Section 515(3)(b), as noted in the Form 145 user manual.

The logic behind both forms is the withholding duty on payments to non-residents. Under the 1961 Act this sat in Section 195, which applies the DTAA rate or the rate in the Act, whichever is lower. That is why Form 146 asks the accountant to assess taxability twice: once under the Act alone, and once under the treaty.

The seven panels. Per the manual, Form 146 has seven panels, and each one shows "Completed" once it is saved:

Who can file. The manual lists four prerequisites. The CA must be registered on the e-Filing portal with their membership number. Their CA ID status must be "Active". They must have a valid Digital Signature Certificate (DSC). And the taxpayer must have assigned Form 146 to them. Form 146 can be filed online or through the offline utility, and the manual says "there is no fixed deadline for submitting it". In practice, though, it must come first: the CA files Form 146, and the remitter then uses its details to complete Part C of Form 145, which is filed before the money is sent.

Worked Example

Take Rohan, a resident software consultant in Bengaluru with a gross income of Rs 30,00,000 in tax year 2026-27. He pays a non-resident data-modelling specialist (an individual, not a company) for project work. For this example only, assume each payment is taxable in India, the specialist has a Tax Residency Certificate, and the CA concludes that a hypothetical withholding rate of 10% applies. The real rate depends on the section and the treaty, and the CA certifies it in panels 4 to 6.

Step 1: May and August. The running total reaches Rs 4,50,000, which is still within Rs 5,00,000, so Rohan files Form 145 Part A for each payment himself. No CA certificate is needed yet.

Step 2: November crosses the line. The Rs 1,20,000 payment takes the total to Rs 5,70,000. Rohan logs in, goes to Authorised Partners > My Chartered Accountants (CA), clicks "Add CA", enters the CA's membership number, and assigns Form 146 under "Forms as per the Income Tax Act, 2025".

Step 3: grossing up for field 19. The manual says the amount in field 19 must be "before deduction of TDS i.e. grossed up". If the specialist is owed Rs 1,20,000 net and Rohan bears the tax, then at the assumed 10% rate the gross amount is Rs 1,20,000 / (1 - 0.10) = Rs 1,33,333. The CA reports Rs 1,33,333 in field 19, and the tax is Rs 13,333. If the CA reported Rs 1,20,000, the TDS would be understated by Rs 1,333. You can test different rates with our TDS calculator.

Step 4: the CA files. The CA chooses the tax year, enters Rohan's PAN, and completes all seven panels. Panel 4 records the section, amount and rate. Panel 5 records the treaty position, and panel 6 records the date of deduction (field 34). The CA then e-verifies using a DSC only and receives a Transaction ID and an Acknowledgement Receipt Number.

Step 5: Form 145 Part C. Rohan enters the Form 146 acknowledgement in Part C of Form 145. The panels are pre-filled from the CA's certificate, and he e-verifies before the bank releases the funds. In February 2027 the whole process repeats, because Form 146 is required "every time" a payment is made once the threshold applies. To see how these payments sit within his own tax bill, Rohan can use the income tax calculator.

Common Mistakes

1. Counting payment by payment instead of the yearly total. The Rs 5,00,000 test applies to "the payment / aggregate of such payments" in the tax year. In Rohan's case, no single payment came close to Rs 5,00,000, yet the total crossed it on 18 November 2026.

2. Reporting the net amount in field 19. The manual requires the gross amount, before TDS. As the table above shows, reporting Rs 1,20,000 instead of Rs 1,33,333 understates the tax by Rs 1,333 on a single payment. The gap grows with every later payment.

3. Treating one certificate as covering the whole year. The manual says Form 146 is needed "every time you make such a payment". Rohan's February 2027 payment of Rs 90,000 needs its own certificate, even though November's was already filed.

4. Claiming treaty relief without the paperwork. Field 28 asks whether DTAA relief is claimed. If it is, the CA must report the recipient's TRC, the nature of the payment, the treaty details, the taxable income and the tax. A treaty claim without a TRC on file is one that cannot be properly certified.

5. Missing the capital-gains disclosure. Field 29(c) asks whether the remittance is a capital gain. If it is, the CA must report its classification, sale price, purchase date and cost, and the gain itself. Sale proceeds sent abroad by a non-resident seller are a common case. Our capital gains calculator helps you work out the gain before the CA certifies it.

6. A DSC that is not registered or has expired. Form 146 can be e-verified "using DSC only". There is no EVC route. A CA whose DSC is not registered on the portal, or whose ID is not "Active", cannot submit, and the remitter's Part C filing is held up.

7. Not validating the UDIN. The UDIN field is optional for now. But the manual says that if the CA enters one, it must be validated on the "View and Update UDIN" screen, both when the form is filled and after it is submitted.

FAQ

Is Form 146 the same as Form 15CB?

In function, yes. The Income Tax Department's user manual states: "As per the Income tax Act 1961, Form 146 is known as Form 15CB." Under the Income-tax Act, 2025, it is listed under "Forms as per Income Tax Act 2025" on the e-Filing portal.

When is Form 146 required?

When a payment to a non-resident (not a company) or a foreign company is taxable in India and the payment, or the total of such payments, exceeds Rs 5,00,000 in the tax year. Below Rs 5,00,000, the remitter files Part A of Form 145 without a CA certificate.

Who can file Form 146?

Only a chartered accountant who is registered on the e-Filing portal with their membership number, has an "Active" CA ID and a registered DSC, and has been assigned Form 146 by the taxpayer. Section 515(3)(b) of the 2025 Act defines the "accountant" for this purpose.

Is there a deadline for filing Form 146?

The manual says "there is no fixed deadline for submitting it". But Form 145 Part C, which relies on Form 146, must be filed before the remittance. In practice, the CA has to finish Form 146 before the payment date.

Can Form 146 be e-verified with an Aadhaar OTP or EVC?

No. Per the manual's step 24, Form 146 is verified "using DSC only". After a successful submission, the CA receives a Transaction ID and an Acknowledgement Receipt Number, and a confirmation is sent to the registered email and mobile.

Do I need Form 146 if I have an Assessing Officer certificate?

No. Above Rs 5,00,000, Form 145 offers two routes: Part B, with an Assessing Officer certificate under Section 395(1) or 395(2), or Part C, with Form 146. You need one of the two, not both.

What amount goes in the remittance field?

Field 19 takes the remittance amount "before deduction of TDS i.e. grossed up". If the payer bears the tax, the CA reports the grossed-up figure, not the net amount the recipient receives. The TDS deducted, and its date (field 34), are reported in panel 6.

This explainer is drawn from the Income Tax Department's Form 146 and Form 145 user manuals on the e-Filing portal. Withholding rates in the worked example are hypothetical and used only to show the arithmetic. The actual rate depends on the nature of the payment and any applicable treaty, and is for the certifying accountant to determine.