The new Income Tax rules, which come into effect from 1 April 2026, have expanded the reporting framework for remittances to non-residents. According to analysts, the newly notified Form No. 146 has introduced enhanced disclosure requirements and greater alignment with regulatory and tax treaty provisions compared to the existing Form 15CB.
A key change is the detailed capital gains reporting framework, wherein taxpayers are now required to furnish transaction-level particulars such as date of acquisition and sale, full value of consideration, cost of acquisition/improvement, and computation of long-term and short-term capital gains separately. This replaces the earlier limited disclosure of aggregate capital gains figures.
According to Amit Maheshwari, Managing Partner, AKM Global, a tax and consulting firm, the new form mandates specific identification details of the remittee, including Permanent Account Number (PAN), if available, Tax Identification Number (TIN) in the country of residence, Tax residency certificate number and expanded address and contact details (email address and contact number), thereby strengthening treaty-based verification and transparency.
The new rules also introduces comprehensive banking and remittance channel disclosures, including IFSC, BSR code, and details of the authorised dealer, along with a requirement to specify whether the remitting bank and authorised dealer are the same.
Form 146 is a chartered accountant certificate required for foreign remittances. It validates TDS compliance and DTAA (Double Taxation Avoidance Agreement) guidelines before the remitter files an online income tax declaration.
The new rules have also formalized a tighter foreign tax credit process. Under Rule 76, taxpayers are required to file Form No. 44 (statement of foreign income and tax) and obtain CA certification. Certification is mandatory for all companies, and other assessees whenever the aggregate foreign tax paid is Rs 1 lakh or more.
“The rule also defers credit on disputed foreign taxes until the dispute is settled and evidenced via Form No. 45, bringing uniform, document‑backed assurance to FTC claims. Certification in Form No 45 is also mandatory where certification was required for Form No 44,” says Amit Maheshwari.
Meanwhile, for the first time, eligibility to certify tax positions is no longer based solely on professional qualification. The new rules introduce hard thresholds — minimum 10 years of experience, revenue benchmarks (Rs 50 lakh for individuals and Rs 3 crore for firms), and even recognition of foreign professionals meeting similar criteria.