The Income-tax Rules, 2026 have introduced a completely revamped framework for reporting foreign remittances by replacing:

• Form 15CA / 15CB (Rule 37BB)
  with
• Form 145 / 146 (Rule 220)

This is not a mere procedural change—it represents a structural overhaul in reporting, documentation, and tax determination for cross-border payments.

1. Change in Legal Framework – Rule 37BB vs Rule 220

Under the new regime:

• Rule 220 governs furnishing of information for payments to non-residents
• It clearly categorizes compliance based on:
  • Amount of remittance
  • Taxability
  • Nature of certification (AO / CA)

As per Rule 220: (Form 145 & 146)

• Part A: ≤ ₹5 lakh
• Part B: > ₹5 lakh with AO certificate
• Part C: > ₹5 lakh with CA certificate (CA Certificate in Form 146)
• Part D: Non-taxable remittances

While the broad classification of Parts (A to D) remains largely consistent with the earlier framework under Rule 37BB, the primary change lies in:

• Replacement of Form 15CA → Form 145
• Replacement of Form 15CB → Form 146

2. Significant Expansion in Remitter Details

Form 145/146 now requires comprehensive profiling of the remitter:

Newly Mandatory Fields:

• Residential Status (residential status as Resident, Non-resident, Resident but not ordinarily resident)
• Status (Individual, HUF, Company, Firm, AOP, etc.) - (Auto fatched from PAN)
• TAN (if available) - (Auto fatched from PAN)
• Email ID & Contact Number (Auto fatched from PAN)

These were not required in earlier Form 15CB, indicating a shift towards identity-based compliance tracking.

3. Strengthened Reporting for Remittee

The new rules significantly enhance global traceability.

Additional Requirements (Mandatory):

• Tax Identification Number (TIN) of country of residence
• Mandatory disclosure even via alternate unique ID if TIN unavailable
• Complete foreign address
• Email & contact details (If Available)

This aligns with international tax transparency standards.

4. Authorised Dealer & Banking Transparency

New disclosures include:

• Whether bank = authorised dealer
• If not, separate selection required
• Reporting of ITDREIN (Optional)

This ensures end-to-end traceability of remittance channels, which was missing earlier.

5. Explicit TDS Computation under the Act

A critical shift:

• Earlier (Form 15CB):
  ❌ No structured requirement to disclose tax rate under the Act (without DTAA)
• Now:
  ✅ Mandatory reporting of:
  • Rate of TDS

This ensures that:

Tax under domestic law is determined first, before applying DTAA relief

6. Additional Details Required for DTAA Reporting

• In case of claiming DTAA benefit, it is mandatory to furnish:
  • Tax Residency Certificate (TRC) Number

7. Pre-Filled Data & System Integration

The rules explicitly state:

• Certain fields will be auto-populated

This enhances:

• Accuracy
• Efficiency
• Reduced duplication

8. Form 146 (CA Certificate) – More Structured

Form 146 now requires:

• Separate section to report the UDIN (UDIN can be updated later)

9. Change in Verification Clause

There is a notable change in the verification/declaration section in Form 145/146 as compared to Form 15CA/15CB.

Key Enhancements:

• The verification is now more detailed and responsibility-driven
• It includes:
  • Confirmation of correctness and completeness of information
  • Acknowledgement of liability for short deduction or non-deduction of tax
  • Acceptance of consequences including interest and penalties under the Act

This reflects a clear shift towards greater legal accountability of the remitter and certifying professional.

Conclusion

The transition from Form 15CA/15CB to Form 145/146 marks a fundamental shift in foreign remittance compliance.