India-United Kingdom DTAA
Treaty signed: June 25, 1993 | Effective from: October 25, 1993
● Live · Rates served from /api/tax-rules/dtaa/GB
Dividends
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Interest
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Royalties
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Capital Gains
Fees for Technical Services
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Key Treaty Provisions
- Comprehensive treaty covering all major income heads: dividends, interest, royalties, FTS, capital gains, pensions
- UK residents can claim Indian TDS as a credit against UK income tax under the credit method
- Permanent Establishment (PE) - business profits taxable in India only if UK company has a PE in India
- The MLI has modified this treaty - Principal Purpose Test (PPT) now applies, denying benefits if the primary purpose was to obtain treaty benefits
- Pension income: taxable only in the country of residence, not the source country
Frequently Asked Questions
What is the DTAA rate for interest income from an NRO fixed deposit for a UK-based NRI?▾
Under the India-UK DTAA, interest income is taxable in India at 15% (vs standard TDS of 30% for NRIs). You must submit TRC and Form 10F to the bank to claim the lower 15% rate.
I am a UK-based Indian freelancer earning consulting fees from India - what TDS applies?▾
Fees for Technical Services (FTS) are taxable at 15% under the India-UK DTAA. The Indian payer must deduct TDS at 15% (instead of 20%) if you provide TRC + Form 10F. You then declare this income in the UK and claim a credit for Indian taxes paid.
Does the Principal Purpose Test under MLI affect India-UK DTAA claims?▾
Yes. India and the UK have both ratified the OECD Multilateral Instrument (MLI). The Principal Purpose Test (PPT) now applies - if tax authorities determine that obtaining a treaty benefit was one of the principal purposes of an arrangement, the benefit can be denied. Genuine investments are unaffected.
Browse all articles
20 articlesArticle 1 of the India-United Kingdom DTAA governs persons covered.…
Article 4 of the India-United Kingdom DTAA governs resident.…
Article 5 of the India-United Kingdom DTAA governs permanent establishment.…
Article 7 of the India-United Kingdom DTAA governs business profits.…
Article 8 of the India-United Kingdom DTAA governs shipping, inland waterways, and air transport.…
Article 9 of the India-United Kingdom DTAA governs associated enterprises.…
Dividends paid by a company resident in one State to a resident of the other State may be taxed in the recipie…
Interest arising in one State and paid to a resident of the other may be taxed in the recipient's State, with …
Royalties paid to a resident of the other State may be taxed in the recipient's State; the source State retain…
FTS - payments for managerial, technical, or consultancy services - are taxed at the treaty rate where a speci…
Article 13 allocates taxing rights over capital gains between India and United Kingdom.…
Article 14 of the India-United Kingdom DTAA governs independent personal services.…
Article 15 sets the taxing rights for salaries earned by an employee of one State who works in the other.…
Article 17 of the India-United Kingdom DTAA governs artistes and sportspersons.…
Article 18 of the India-United Kingdom DTAA governs pensions.…
Article 19 of the India-United Kingdom DTAA governs government service.…
Article 23 sets out the mechanism by which double taxation is eliminated - typically through a foreign tax cre…
MAP allows the competent authorities of India and United Kingdom to resolve disputes - particularly transfer p…
Allows the competent authorities to exchange information necessary to apply the treaty or domestic tax laws.…
Treaty benefits are denied where the principal purpose of the transaction was to obtain them.…
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