The India-Qatar DTAA Just Got Its First Full Rewrite Since 1999.

The revised India-Qatar DTAA was signed on 18 February 2025. CBDT notified it on 24 October 2025 (Notification 154/2025), and it enters into force in India from 1 April 2026.

Until 31 March 2026, the old 1999 treaty still governs. From 1 April 2026, the new treaty replaces it entirely. If you're filing FY 2025-26 returns, use the old rates. For FY 2026-27 onwards, the new rates apply.

**Dividends (Article 10):** 5% if the beneficial owner is a company holding at least 25% of the capital of the paying company. 10% in all other cases. Retail Qatari-Indian investors with small Indian stock holdings fall into the 10% bucket.

**Interest (Article 11):** 10%. Same as the old treaty. No change for FD interest, NRO savings, or bond income.

**Royalties and Fees for Technical Services (Article 12):** 10%. This is a meaningful cap. The old treaty was less clear on FTS, which caused interpretation disputes. Now it's explicit.

**Capital gains (Article 13):** Source-country taxation for shares, property, and business assets. Qatar doesn't tax capital gains domestically, so Qatari NRIs still pay the India rate — 12.5% on equity LTCG post-Budget 2024.

The new treaty includes a Principal Purpose Test (PPT) aligned with BEPS Action 6. In plain English: if the main purpose of an arrangement is to get a treaty benefit, the benefit can be denied.

For a retail Qatari-Indian NRI with Indian FDs and mutual funds, this doesn't change anything. You're using the treaty for its intended purpose, avoiding double tax on ordinary investment income.

It matters if you're routing a business or investment through a Qatari entity purely to grab a better rate. If the structure has no economic substance in Qatar, the PPT can knock it out. That's a corporate and HNI concern, not a salaried-NRI concern.

**Update your bank and AMC forms.** Your Form 10F on file probably cites the old 1999 treaty articles. Ask your Indian bank and mutual fund house to update the Form 10F and attach a fresh TRC from the Qatar General Tax Authority so the new rates kick in from 1 April 2026.

**Get a current TRC.** The Qatar GTA issues TRCs valid for the tax year. If you haven't applied in 2026, apply now so you're ready for the FY 2026-27 filing window.

**Check your AY 2025-26 filing.** You file that return under the old treaty. If you missed claiming treaty rates for the current year, you can still file a revised return or rectification under Section 154 to capture the benefit before moving to the new regime next year.

**Past-year recovery.** The old India-Qatar DTAA is still live for past years. If you never claimed DTAA benefits, you can file condonation of delay under Section 119(2)(b) for up to 5 Assessment Years back, using the old treaty rates. We handle this end-to-end.