Chartered Accountants◆Practising since 2016

UK to India · Tax treaty

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

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

In brief

Under the India–UK tax treaty (Signed 1993), India's tax on payments to a UK resident is capped at 10% (15% for certain property vehicles) on dividends, 15% (10% for banks) on interest and 15% (10% for equipment) on royalties. Technical fees: 15% (10% for equipment-related services).

What is specific to UK companies

The UK treaty sets 10% on most dividends, 15% on interest (10% for banks) and 15% on royalties and technical fees. Its 90-day services test is shorter than in many treaties, so long UK visits to India need tracking.

Treaty rates

IncomeIndian tax under the treaty
Dividends10% (15% for certain property vehicles)
Interest15% (10% for banks)
Royalties15% (10% for equipment)
Technical service feesTechnical fees: 15% (10% for equipment-related services).
Gains on Indian sharesLeft largely to domestic law, so India can tax the gain.

Permanent establishment

The treaty has a 90-day services test, much shorter than many treaties.

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 UK rules change often; confirm the current position before acting. UK law points should be confirmed with a UK adviser.

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