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India-United States DTAA

Treaty signed: September 12, 1989  |  Effective from: December 18, 1990

● Live · Rates served from /api/tax-rules/dtaa/US

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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NRI / Practical Note: US citizens and green card holders are taxed on worldwide income by the US regardless of DTAA. India-sourced income must be declared in the US with a foreign tax credit (Form 1116). Conversely, US-source income of Indian residents can often claim reduced DTAA withholding rates with a W-8BEN form.

Key Treaty Provisions

  • Article 25 (Limitation on Benefits) - treaty benefits restricted to bona fide residents; conduit structures do not qualify
  • India-US DTAA covers all types of income: business profits, dividends, interest, royalties, capital gains, salaries, pensions
  • Saving Clause: US retains the right to tax its citizens/residents as if no DTAA existed (so US citizens in India get limited relief)
  • MLI (Multilateral Instrument) ratified by India but US has not ratified - old bilateral treaty terms still apply
  • FBAR and FATCA reporting obligations apply to US persons holding Indian accounts/assets - DTAA does not override US domestic reporting

Frequently Asked Questions

Does the India-US DTAA help me avoid double tax on salary in India?

If you are a US citizen working in India, the Saving Clause in the India-US treaty means the US taxes you regardless. However, you can claim a foreign tax credit (Form 1116) in the US for Indian taxes paid, largely eliminating double taxation. The DTAA helps Indian residents receiving US-source income get lower withholding rates (15% on dividends, 15% on interest).

What TDS rate applies on royalties paid by an Indian company to a US company?

Under the India-US DTAA, royalties (other than copyright) are taxable at 15% in India - lower than the standard 20% applicable without DTAA. The US company must furnish a Tax Residency Certificate and Form 10F to claim the lower rate.

Is DTAA relief available to US LLCs receiving income from India?

The India-US DTAA is one of the few India treaties that contains a Limitation on Benefits clause. US LLCs must qualify under the treaty's LOB provisions (public company test, ownership/base erosion test, etc.) to be entitled to DTAA benefits. Consult a tax advisor for specific structures.

Browse all articles

20 articles
Art. 1
Persons Covered

Article 1 of the India-United States DTAA governs persons covered.

Art. 4
Resident

Article 4 of the India-United States DTAA governs resident.

Art. 5
Permanent Establishment

Article 5 of the India-United States DTAA governs permanent establishment.

Art. 7
Business Profits

Article 7 of the India-United States DTAA governs business profits.

Art. 8
Shipping, Inland Waterways, and Air Transport

Article 8 of the India-United States DTAA governs shipping, inland waterways, and air transport.

Art. 9
Associated Enterprises

Article 9 of the India-United States DTAA governs associated enterprises.

Art. 1015% portfolio / 25% if s…
Dividends

Dividends paid by a company resident in one State to a resident of the other State may be taxed in the recipie

Art. 1115%
Interest

Interest arising in one State and paid to a resident of the other may be taxed in the recipient's State, with

Art. 1215% general / 20% on cop…
Royalties

Royalties paid to a resident of the other State may be taxed in the recipient's State; the source State retain

Art. 12A15%
Fees for Technical Services

FTS - payments for managerial, technical, or consultancy services - are taxed at the treaty rate where a speci

Art. 13
Capital Gains

Article 13 allocates taxing rights over capital gains between India and United States.

Art. 14
Independent Personal Services

Article 14 of the India-United States DTAA governs independent personal services.

Art. 15
Income from Employment

Article 15 sets the taxing rights for salaries earned by an employee of one State who works in the other.

Art. 17
Artistes and Sportspersons

Article 17 of the India-United States DTAA governs artistes and sportspersons.

Art. 18
Pensions

Article 18 of the India-United States DTAA governs pensions.

Art. 19
Government Service

Article 19 of the India-United States DTAA governs government service.

Art. 23
Elimination of Double Taxation

Article 23 sets out the mechanism by which double taxation is eliminated - typically through a foreign tax cre

Art. 25
Mutual Agreement Procedure (MAP)

MAP allows the competent authorities of India and United States to resolve disputes - particularly transfer pr

Art. 26
Exchange of Information

Allows the competent authorities to exchange information necessary to apply the treaty or domestic tax laws.

Art. 29
Entitlement to Benefits (PPT / LOB)

Treaty benefits are denied where the principal purpose of the transaction was to obtain them.

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