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 adds a Principal Purpose Test (PPT) aligned with BEPS Action 6 / MLI Article 7. The PPT permits the competent authority to deny a treaty benefit where obtaining that benefit was one of the principal purposes of the arrangement and granting it would be contrary to the object of the relevant treaty provision.

A retail Qatari-Indian NRI claiming Article 11 on NRO interest or Article 10 on Indian dividends is using the treaty for its intended purpose — relief from juridical double tax on ordinary investment income. The PPT does not bite on these claims.

The PPT targets structures routed through a Qatari entity solely for the rate — for example, a Qatari intermediate holding company with no operational substance in Doha interposed to access the 5% dividend cap. That is a corporate and HNI structuring issue under Article 29 of the new treaty, 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.