Chartered Accountants◆Practising since 2016

Singapore to India · Tax treaty

The India–Singapore tax treaty: rates, permanent establishment and gains

CA Utsav Dogra, Chartered Accountant, ICAI M. No. 542375 · Updated

In brief

Under the India–Singapore tax treaty (1994, with protocols and the MLI), India's tax on payments to a Singapore resident is capped at 10% (25% holding), 15% otherwise on dividends, 10% or 15% on interest and 10% on royalties. Technical fees: 10%.

What is specific to Singapore companies

Dividends are taxed at 10% for a 25% holding and 15% otherwise; interest at 10% or 15%; royalties and technical fees at 10%. India can tax gains on shares acquired on or after 1 April 2017, and Article 24A denies the share-gains benefit to shell or conduit companies.

Treaty rates

IncomeIndian tax under the treaty
Dividends10% (25% holding), 15% otherwise
Interest10% or 15%
Royalties10%
Technical service feesTechnical fees: 10%.
Gains on Indian sharesIndia can tax gains on shares acquired on or after 1 April 2017.

Permanent establishment

Service PE threshold: over 90 days in a fiscal year, cut to 30 days where the services go to a related enterprise.

Our services

How SU and Company helps

We plan and document how money moves back to the parent, at the right treaty rate.

  • Dividend, royalty, fee and interest planning
  • Treaty withholding and remittance paperwork
  • Board and FEMA steps for dividends and buybacks
  • Indian figures and certificates for the parent's tax relief

Questions

Does the treaty always beat Indian domestic rates?

The lower of the treaty and domestic rate applies, provided the recipient is the beneficial owner and holds a valid residency certificate.

General information as at 5 November 2026, not advice for a particular case. Indian and Singapore rules change often; confirm the current position before acting. Singapore law points should be confirmed with a Singapore adviser.

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