The quarter that closed on 30 September 2026 was the second under India's new tax law, and many clients still walk into their bank asking for Form 15CA before sending money abroad. The form no longer exists under that name. Since 1 April 2026, Form 15CA has been replaced by Form 145, and the chartered accountant's certificate once known as Form 15CB is now Form 146. For a resident individual sending money for investment under the Liberalised Remittance Scheme, the more useful answer is that neither form is usually needed at all.
That point matters more this year because more clients are remitting for investment. According to RBI data reported by Business Standard on 25 August 2026, remittances for equity and debt investment under the scheme more than doubled in June from a year earlier. Each of those transfers raises two separate compliance questions, one about Form 145 and one about tax collected at source, and clients often treat them as one. The guide to TCS on foreign remittance covers the second question in full. This article explains the first, shows where the exemption ends and sets out what an advisor should check before a client remits.
What Form 15CA was and what replaced it
Form 15CA was a declaration filed before paying money to a non-resident, so that the tax department could track payments that might be taxable in India. When the Income-tax Act, 2025 replaced the 1961 Act, the forms were renumbered under the Income-tax Rules, 2026. The Income Tax Department's FAQs on Form 145 describe it as the form earlier known as Form 15CA. It is filed on the e-filing portal before the remittance is made, and a copy goes to the bank that sends the money.
Form 145 has four parts. Part A covers payments that do not exceed ₹5 lakh in a tax year. Parts B and C cover larger payments, backed either by a certificate from the Assessing Officer or by Form 146, the certificate in which a chartered accountant confirms the taxability of the payment and the treaty position. Part D covers payments that are not chargeable to tax in India. Failing to furnish the information can attract a penalty of up to ₹1 lakh under section 462 of the new Act.
Why most LRS remittances do not need Form 15CA
Rule 220 of the Income-tax Rules, 2026 carries forward the exemption that advisors relied on under the old rules. No information is required when an individual makes a remittance that does not need the RBI's prior approval, and the department's FAQs state that this covers payments by an individual under the Liberalised Remittance Scheme. The RBI's FAQs on the scheme allow each resident individual to remit up to USD 250,000 in a financial year without approval. A client who stays within that limit does not file Form 145 for the transfer.
The rule also lists purpose codes for which no form is needed, whoever sends the money. They include Indian investment abroad in equity, in debt and in real estate, as well as remittances towards personal gifts and donations. An LRS investment remittance by a resident individual therefore falls outside Form 145 on two separate grounds. When a bank asks for the form anyway, the first thing to check is the purpose code on the remittance application, because the exemption depends on how the transfer is classified.
Where the exemption stops
The individual exemption rests on two facts, that the remitter is an individual and that no RBI approval is needed. If either changes, the position changes. The RBI's FAQs state that anything above the USD 250,000 limit needs its prior approval, so a client who has already used the year's limit cannot rely on the individual exemption for a further transfer. Gifts within a family also need care, because although personal gifts sit on the exempt list, the clubbing of income and gift tax questions remain with the client and their CA.
The exemption does not cover a client's company, partnership or trust either. When a family business pays a foreign consultant or buys software from an overseas vendor, it is a payment to a non-resident by someone who is not an individual. Form 145 then generally applies unless the purpose code sits on the exempt list, and above ₹5 lakh in a tax year the bank will expect either an Assessing Officer's certificate or a Form 146 from a chartered accountant. Banks also report the remittances they handle in a quarterly statement on Form 147, due within 15 days of the end of each quarter, which for the quarter just ended falls on 15 October 2026.
TCS is a separate question
A client who needs no Form 145 still pays tax collected at source at the bank. TCS sits in a different provision, section 394 of the Income-tax Act, 2025, and applies to LRS remittances whether or not Form 145 is needed. For tax year 2026-27, money sent abroad for investment attracts TCS of 20 per cent on the amount above ₹10 lakh, and that threshold applies per person across all purposes in the year. Education and medical remittances attract 2 per cent above the same threshold.
For example, a client who remits ₹40 lakh for an overseas investment in tax year 2026-27, with no earlier remittances that year, pays TCS of 20 per cent on the ₹30 lakh above the threshold, which is ₹6 lakh. That amount is not a final tax, because the client can claim it against their income tax for the year. The bank reports it on Form 133, the TCS certificate that replaced Form 27D, and the explainer on Form 133 and TCS certificates shows how to track it. The form a client keeps asking about is often the one that does not apply, while the one that affects cash flow arrives months later.
None of this paperwork changes the investment itself. A remittance that clears every form still carries the risks of the asset it funds, including loss of capital, illiquidity, falling property values, tenants leaving, distributions not being paid and currency movements. For private property, the guide to US commercial real estate for advisors explains how those risks arise and what to ask a sponsor before a client commits.
What advisors should check before a client remits
The checks are short and are best done before the client visits the bank. Done in this order, they settle the Form 145 question first and the cash flow question second.
- Confirm that the client is remitting as an individual under the Liberalised Remittance Scheme, and that the year's total, including the planned transfer, stays within USD 250,000.
- Check that the purpose code on the bank's application matches the use of the money, such as investment abroad in equity, debt or real estate.
- Add up the client's remittances so far in tax year 2026-27, work out how much falls above the ₹10 lakh threshold, and plan for the cash that TCS will hold until the return is filed.
- Where a family company, firm or trust is making a payment abroad, bring in the CA early, because Form 145 and possibly Form 146 must be in place before the bank releases the money.
Advisors who introduce eligible clients through Raveum's partner page will recognise the pattern. The platform handles KYC, the investment agreements and the US tax forms, while the client's Indian tax position stays with the client and their CA. On that Indian side, an investment remittance by a resident individual usually needs no Form 145, but the TCS on it still needs planning.
The client who asks for Form 15CA is asking a reasonable question with an out-of-date label. The renumbering changed the form, not the logic, and that logic still separates an individual's LRS transfer from a business paying a non-resident. Advisors who can explain that line save clients an unneeded certificate and catch the cases where one is required, while the TCS guide for advisors and CAs covers the cost that every investment remittance above the threshold carries.
Frequently asked questions
Is Form 15CA still required in 2026?
Form 15CA no longer exists under that name. From 1 April 2026, under the Income-tax Rules, 2026, it has been replaced by Form 145, and the accountant's certificate in Form 15CB has become Form 146. The purpose is unchanged, which is reporting payments to non-residents before the money leaves India.
Does a resident individual need Form 145 for an LRS remittance?
Usually not. Rule 220 says no information is needed when an individual's remittance does not require the RBI's prior approval, which covers transfers under the Liberalised Remittance Scheme within USD 250,000 a financial year. Investment abroad in equity, debt and real estate is also on the rule's list of exempt purpose codes.
When is Form 146, earlier Form 15CB, required?
Form 146 is a chartered accountant's certificate on the taxability of a payment to a non-resident. It supports Part C of Form 145, which applies when payments exceed ₹5 lakh in a tax year and no certificate from the Assessing Officer has been obtained. Exempt LRS remittances by individuals do not need it.
What is the penalty for not filing Form 145 when it is required?
The Income Tax Department's FAQs state that failing to furnish Form 145 when it is required can attract a penalty of up to ₹1 lakh under section 462 of the Income-tax Act, 2025. The form must be filed before the remittance is made, so the check belongs before the bank visit.
Does TCS apply if Form 145 is not required?
Yes. TCS falls under section 394 of the Income-tax Act, 2025 and is separate from Form 145. For tax year 2026-27, investment remittances attract TCS of 20 per cent on the amount above ₹10 lakh per person. The client can claim it against their income tax using the Form 133 certificate.
Does clearing the remittance paperwork make an overseas investment suitable for a client?
No. Form 145 and TCS decide how money leaves India, not whether an investment suits the client. Private overseas property can lose value, can be hard to sell, may not pay distributions and is exposed to currency movements, so suitability depends on the client's goals, liquidity needs and wider portfolio.
This article is for general education and is not tax, legal or investment advice. Rules change and depend on individual circumstances. All investing involves risk, including loss of capital, illiquidity and currency movements. Offerings on Raveum are available to eligible investors only and are not open to the general public.
