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INTERNATIONAL TAX · CA CERTIFICATE · FORM 15CB / 146
Form 15CB certification assistance for eligible cross-border payments. Understand when a Chartered Accountant must certify the taxability, treaty treatment and withholding details of an outward remittance. For payments on or after 1 April 2026, the corresponding accountant certificate is Form 146.
✓ CA certificate applicability
✓ DTAA & TDS review
✓ Form 146 verification
TAXABILITY · TREATY REVIEW · CA CERTIFICATION
Assess payment nature, taxability and certificate need.
Organise agreement, recipient and treaty documents.
Check certificate details and DSC acknowledgement.
✓ Taxability review
✓ CA certification
✓ Form 146 records
CA CERTIFICATE · FOREIGN PAYMENTS · TAX EVIDENCE
Tell us the payment nature, recipient country, approximate amount and whether an accountant certificate is requested for a Form 145 Part C filing. A qualified Chartered Accountant must independently assess and issue any applicable certificate.
Please do not submit banking credentials, OTPs, full PAN numbers, login passwords or confidential contracts in the public enquiry form. Sensitive documents should be shared securely after an engagement is agreed.
Share a broad description of the foreign payment, beneficiary country, tax-document position and whether the proposed remittance needs CA certification.
A focused guide to Form 15CB / Form 146: when accountant certification is required, what a CA examines, the supporting evidence and the e-Filing workflow.
Review the purpose of the CA certificate, chargeability and DTAA tests, withholding details, taxpayer-to-CA assignment, seven Form 146 panels, DSC verification and record retention.
Form 15CB is the accountant’s certificate used in specified outward payments to non-residents or foreign companies. The Chartered Accountant evaluates the character of the income, chargeability to Indian tax, applicable withholding and the documents supporting the transaction. It is a professional tax determination, not a routine declaration completed by the payer.
The certificate is relevant to a remittance-specific tax review and can support the payer’s corresponding remittance-information return when the accountant route applies. The CA must form an independent conclusion based on facts; the existence of an invoice or a bank request does not itself determine the tax position.
Form 15CB
Form 146
Registered Chartered Accountant
Taxability and withholding
Practical note: Form 15CB is different from the information declaration submitted by the remitter. Certification cannot be substituted by a generic template or a self-declaration.
For relevant remittances made on or after 1 April 2026, Form 146 under the Income-tax Act, 2025 and Income-tax Rules, 2026 is the prescribed accountant certificate corresponding to earlier Form 15CB. The approved service name remains Form 15CB Certification Assistance for familiarity with the established terminology.
When reviewing an earlier-year remittance or an existing certificate, distinguish its actual payment date from the period when the underlying expense accrued. Previously furnished Form 15CB documents do not become void simply because the legislation changed, but the correct current-year form should be selected for new transactions.
Income-tax Act, 1961
Income-tax Act, 2025
Form 15CB
Form 146
Practical note: Use the remittance date and the applicable law to select the form; do not simply reuse a downloaded PDF from an earlier transaction.
Under the current reporting framework, Form 146 is generally linked to a chargeable remittance where the payment or aggregate exceeds ₹5 lakh in the tax year and the payer follows the accountant-certificate route for Form 145 Part C. Where the relevant Assessing Officer certificate or order supports the applicable Part B route, a Form 146 certificate is not automatically required as well.
The review must begin with the payment’s tax character and the particular reporting route. Excluded payments and non-chargeable payments may have different information-filing outcomes; the amount alone never establishes that an accountant certificate is compulsory.
Taxable foreign remittance
Over ₹5 lakh in tax year
Form 145 Part C
Applicable AO certificate
Practical note: Where there is uncertainty about taxability or a statutory reporting exception, get the facts evaluated before concluding whether a certificate is required.
The payer is responsible for describing the transaction accurately, providing underlying records, appointing the Chartered Accountant on the e-Filing portal and completing the related remitter declaration as required. The CA reviews the facts, determines the certification position and electronically files Form 146 using their professional credentials.
This division is important for compliance. The certificate is not issued by a bank, an unregistered intermediary or the remitter. An advisory business can help coordinate documentation and the process, while the legal certification must be made by an eligible Chartered Accountant.
Supplies accurate records
Independent examination
Remittance checks
CA assigned by taxpayer
Practical note: Confirm the CA’s active portal registration and registered Digital Signature Certificate before attempting electronic submission.
The CA first identifies what the overseas recipient is actually being paid for. A consultancy agreement, licensing contract, interest schedule, software arrangement or property transaction can involve different source and character-of-income considerations even where the remitter uses the same bank.
Contracts, statements of work, deliverables, place of performance, beneficiary status and invoice terms should be compared. A billing description such as “service fees” may not answer whether a payment constitutes royalty, fees for technical services, business profits, interest or another taxable category.
Agreement / work order
Invoice and deliverables
Legal and tax status
Income characterization
Practical note: Inconsistent contract and invoice descriptions should be resolved before recording the income category in the certificate.
The accountant examines whether the amount is chargeable to tax in India under the relevant domestic-law provisions. Relevant questions may include where income accrues or arises, whether it is deemed to arise in India and whether the transaction has a taxable Indian nexus.
An outward payment permitted by the bank or FEMA requirements is not automatically exempt from income tax. Likewise, a payment made abroad is not taxable merely because money leaves India. A written basis for the chargeability conclusion helps the remitter and CA reconcile Form 146 with withholding records.
Indian tax chargeability
Source and nexus
Supporting facts
Reasoned tax conclusion
Practical note: Keep factual assumptions explicit; a certificate relying on an incorrect recipient status or place of service can misstate the tax result.
Where the foreign recipient seeks treaty treatment, the CA examines the applicable Double Taxation Avoidance Agreement alongside domestic law. Treaty residence, the relevant treaty article and conditions attached to beneficial treatment must be supported by the documents and transaction facts.
The review should also consider whether the payment involves a permanent establishment or another condition relevant to that treaty article. Treaty benefits are not automatic simply because two countries have a treaty; the claimed article and applicable eligibility requirements must be evaluated for the actual payment.
Relevant DTAA
Applicable treaty article
Benefit eligibility
Recipient declarations
Practical note: A lower treaty rate is not selected merely because it appears on an online chart; the facts and documentation must support it.
For a treaty claim, the CA may need to review a foreign Tax Residency Certificate, supplementary information corresponding to Form 10F / current Form 41 where applicable, and declarations about beneficial ownership or other treaty conditions. These serve as supporting evidence for the accountant’s assessment.
This chapter focuses only on how such records affect Form 146 certification. The process of applying for a TRC or separately filing Form 10F is covered on the dedicated approved Online Tax Filings service pages and is not reproduced here.
Foreign TRC
Form 10F / Form 41
Recipient declarations
Validate treaty claim
Practical note: If documents are incomplete, identify the missing basis before claiming an advantageous treaty treatment.
The certificate records the accountant’s determination of the applicable withholding basis. Rate analysis should consider the appropriate domestic or treaty treatment, the chargeable amount and whether the payment terms specify a net-of-tax amount requiring a contractual gross-up computation.
The current Form 146 manual distinguishes the remittance amount before deduction of tax and contains a separate TDS panel. Reconcile the tax calculation to the actual invoice, deduction data, contract terms and any tax already deposited, rather than assuming a standard rate for every foreign supplier.
Applicable TDS basis
Gross vs net payment
Withholding working
Tax deducted details
Practical note: The tax rate depends on the actual payment facts and governing provisions; do not rely on a fixed universal non-resident TDS percentage.
Prepare the foreign recipient’s legal identity and tax residence information, remitter identification, relevant agreements, invoices, nature-of-service descriptions, proposed bank transfer particulars and supporting tax declarations. Depending on the case, tax computation workings and treaty documents may also be necessary.
Organise records so the CA can trace each form entry to a source document. If the contract, invoice and payment instruction name different entities or amounts, these differences should be clarified before certification. Sensitive identity and banking records should be exchanged through a secure document workflow.
Agreement and invoice
Identity and residence
Remittance particulars
Computation and declarations
Practical note: The exact document set varies with the transaction; a one-size-fits-all checklist cannot replace the CA’s case-specific request.
The taxpayer signs into the Income Tax e-Filing portal, navigates to Authorised Partners → My Chartered Accountants (CA), adds the eligible accountant using their membership number and assigns Form 146 under the Income-tax Act, 2025 forms. The form assignment must be submitted for the accountant to act.
The CA needs an active portal profile, valid professional details and an appropriately registered DSC. Incorrect membership numbers, an unaccepted assignment or an expired DSC can interrupt the certificate submission workflow even if the underlying tax calculation has been completed.
My Chartered Accountants
CA membership number
Form 146
Registered DSC
Practical note: Only appoint a CA authorised to make the professional certification; account access and portal passwords should not be shared with third parties.
The current e-Filing manual describes seven panels: remitter, recipient, remittance, domestic-law taxability, treaty taxability, TDS details and verification. The CA reviews each panel separately, with particulars of the payer and recipient and remittance information aligned to the evidence.
The filing sequence includes selection of the correct tax year, validation of recipient details, RBI purpose information where applicable, taxable amount and deduction figures, followed by preview. The certificate should be internally consistent; saving a panel as completed is not a substitute for checking its legal conclusions.
Parties and payment
Domestic law
Treaty and TDS
Verification
Practical note: Form 146 is the CA certificate: the payer’s Form 145 Part C should not be confused with these seven accountant panels.
After completing the form, the accountant reviews a preview, e-verifies using a registered Digital Signature Certificate and retains the successful filing acknowledgment. The portal-generated acknowledgment reference connects the CA certificate to the remitter’s subsequent information-filing step where Part C applies.
Preserve the certified form, proof of verification, acknowledgment details and supporting tax workings with access restricted to authorised personnel. The e-Filing portal’s current instructions regarding UDIN, if entered, should be followed rather than assuming that the certificate’s internal numbering and portal acknowledgment are interchangeable.
CA DSC
Filed acknowledgment
Form 146 ARN
Certification papers
Practical note: Test the correct acknowledgment number and remitter association before proceeding with the payer’s Part C declaration.
Once Form 146 has been filed by the assigned CA, the payer can use its acknowledgment reference for the relevant Form 145 Part C filing. The portal prefills information from the filed accountant certificate, which the payer should check carefully against the proposed remittance and bank documents.
This is the interface between two separate obligations: the CA certifies the tax determination in Form 146, and the payer makes the applicable Form 145 information declaration. The general Parts A/B/D filing procedures are covered on the separate approved Form 15CA Filing page.
CA files Form 146
Payer selects Part C
Certificate ARN
Prefilled form details
Practical note: Do not proceed with Part C using another taxpayer’s certificate or an acknowledgment connected to a different remittance.
Mistakes include incorrect recipient residence, an unsupported treaty rate, missed gross-up terms, incomplete contract facts, inconsistent remittance values, a mismatched RBI purpose code and a failed CA assignment or DSC verification. A form can be syntactically complete while the certified tax analysis remains inconsistent.
A pre-filing review should compare the transaction evidence with domestic-law taxability, DTAA conclusion, withholding computations, each Form 146 panel and the prospective bank payment. A clear working-paper trail supports a defensible certificate and reduces avoidable correction work later.
Recipient and contract
Treaty and taxability
Gross amount and TDS
DSC and ARN
Practical note: Professional certification is an independent CA function. Generic guarantees of exemption or fixed TDS treatment should be avoided.
It is a Chartered Accountant’s tax determination certificate for specified payments to non-residents or foreign companies, examining chargeability, treaty provisions and applicable withholding.
No. A certificate is linked to qualifying taxable remittances following the accountant route, rather than every foreign bank transfer. Check the payment facts, prescribed aggregate threshold and the relevant alternative certificate route.
For relevant payments on or after 1 April 2026, Form 146 under the 2025 Act is the current accountant certificate corresponding to earlier Form 15CB.
A Chartered Accountant registered and active on the e-Filing portal, assigned the form by the taxpayer and equipped with a registered valid DSC.
It is one element in deciding whether a qualifying chargeable payment falls within the accountant-backed Form 145 Part C route. A payment above ₹5 lakh does not by itself prove CA certification is mandatory.
Yes. In qualifying cases, a relevant Assessing Officer certificate or order supports the Form 145 Part B route; the taxpayer should not automatically request a separate Part C certificate.
Treaty relief must be supported by the recipient’s residence and applicable requirements. The CA should review the relevant foreign TRC and supplementary evidence where needed.
The commercial agreement, invoice, payment description, recipient details, residence proof, tax computations and relevant bank and treaty documentation are commonly reviewed, with additional records depending on the case.
The payer uses Authorised Partners → My Chartered Accountants, adds the CA using membership details and assigns Form 146 under the Income-tax Act, 2025.
Yes. The current Form 146 e-Filing workflow requires the CA to have a valid registered DSC for electronic verification.
After the CA e-files Form 146, the payer refers to its acknowledgment while preparing the relevant Form 145 Part C and reviews the prefilled remittance information.
Only an appropriately qualified and registered Chartered Accountant can sign and submit the statutory certificate. Online Tax Filings can discuss documentation and assist with coordination; actual certification remains the professional responsibility of the authorised CA.
Use the Income Tax Department’s official guides for CA assignment, the Form 146 seven-panel filing workflow, taxability and treaty fields, DSC verification and the link to Form 145 Part C. Statutory rules and portal screens may change; verify the applicable tax year before filing.
Important: From 1 April 2026 the corresponding accountant certificate is Form 146. The earlier Form 15CB guidance remains relevant to earlier-law certifications. Statutory certification must be completed by an eligible Chartered Accountant.
Online Tax Filings can help clarify certificate applicability, organise the underlying payment and treaty documents and coordinate the Form 146 process with an appropriately qualified Chartered Accountant where necessary.
For an initial discussion, share the broad payment category, country of recipient, approximate amount and whether the proposed Form 145 reporting route is Part C. The CA makes the final independent tax determination and certification.
Do not share PINs, passwords, OTPs, complete PAN numbers, full account details or private tax documents in the open website enquiry form.
CA CERTIFICATION · TREATY REVIEW · FOREIGN PAYMENTS
Form 15CB / Form 146 document preparation guidance, accountant workflow coordination and practical support in reviewing remittance tax questions. Certification is carried out by an authorised Chartered Accountant.
Cross-border income-tax guidance, remittance documentation coordination and business advisory. Accountant certification is issued only by a qualified, authorised Chartered Accountant.
Thoughtful documentation. Careful tax decisions.
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