The India-Qatar DTAA Just Got Its First Full Rewrite Since 1999.
TL;DR
Effective 1 April 2026. Dividends drop to 5% or 10% depending on the ownership test. Royalties and fees for technical services cap at 10%. A modern anti-abuse article kicks in. Everything Qatari Indians need to know in 4 minutes.
By Vipul Sharma, Founder
Reviewed by Preetesh Maloo, Chartered Accountant, NRI Tax Partner
The dates that matter
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.
What the new rates look like
**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.
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The PPT clause: what's new
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.
What Qatari Indians should do right now
**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.
Country guides mentioned
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The exceptions that change the answer
Where the general rule stops applying to you
Every rule below has a carve-out, a cut-off date or a condition that flips the answer. These are the ones that decide real cases.
LTCG rate: assets other than STT-paid listed equity (includes property)
Right now: 12.5% without indexation
Where it works differently
- A RESIDENT individual or HUF sells land or a building acquired before 23 July 2024
- May elect the lower of 12.5% without indexation or 20% with indexation.
- Grandfathering proviso inserted by Finance (No. 2) Act 2024.
- A NON-RESIDENT sells the same property
- 12.5% without indexation only. The election is NOT available.
- The grandfathering proviso is expressly limited to resident individuals and HUFs. This is the highest-value NRI distinction on the site.
- Shares or debentures of an Indian company were bought in convertible foreign exchange by a non-resident
- The first proviso to s.48 computes the gain in that foreign currency, neutralising rupee depreciation. This is separate from, and not lost with, indexation.
- First proviso to s.48 survives the 2024 changes.
- Adding surcharge and cess
- Surcharge on capital gains under s.111A/112/112A is capped at 15%, plus 4% health and education cess.
- The cap applies to gains under s.111A, s.112 and s.112A.
Commonly got wrong
- NRIs can choose 20% with indexation on property bought before July 2024. The election is resident-only. Stating otherwise understates an NRI's tax, which is the worst direction to be wrong in.Residents may elect 20% with indexation for pre-23-July-2024 land and buildings. Non-residents get 12.5% without indexation, full stop.
- LTCG on property is 20%. Stale since 23 July 2024 unless the transfer predates it.12.5% for transfers on or after 23 July 2024.
Rectification window under s.154
Right now: 4 years from the end of the financial year in which the order was passed
Where it works differently
- The error is a missing TDS credit or a mis-picked figure
- Rectification is faster and cheaper than an appeal, and there is no fee.
- s.154 covers a mistake apparent from the record.
- The point needs argument or fresh evidence
- s.154 will not carry it. That is an appeal under s.246A.
- 'Apparent from the record' excludes debatable questions.
Commonly got wrong
- Any wrong assessment can be rectified. Only a mistake apparent on the face of the record. A debatable issue needs an appeal.Rectification fixes obvious errors within four years. Anything arguable goes to the Commissioner (Appeals) within 30 days.
Tax on royalty and fees for technical services paid to non-residents
Right now: 20% plus surcharge and cess
Where it works differently
- A treaty applies and is more beneficial
- The treaty rate governs, commonly 10-15%. The doubling of the domestic rate made treaty claims worth far more.
- s.90(2). Requires TRC and Form 10F (Form 41 from 1 Apr 2026).
- The India-US or India-UK treaty applies to FTS
- The make-available test can remove the income from Indian tax entirely, not merely reduce the rate.
- Article 12 of both treaties.
- Claiming the treaty rate
- A foreign company must file an Indian return to take the DTAA rate over s.115A.
- Condition attached to the FA 2023 amendment.
Commonly got wrong
- Royalty and FTS to non-residents are taxed at 10%. Doubled to 20% from 1 April 2023.20% plus surcharge and cess under domestic law from 1 April 2023, or the treaty rate (often 10-15%) if you hold a TRC and file the return.
Treaty rate on Indian dividends
Right now: Domestic rate 20% plus surcharge and cess; most treaties cap it at 10-15% under Article 10
Where it works differently
- A TRC and Form 10F are furnished to the registrar or company
- The treaty rate applies at source. Without them the full 20% plus surcharge and cess is deducted and you recover it by filing.
- s.90(4) and (5).
- The exact rate matters
- It is per treaty, not a single number. Check the country entry. Some treaties are 10%, some 15%, and Italy's dividend article can be WORSE than the domestic rate.
- Never quote one figure across countries.
- Claiming the treaty rate
- The s.115A(5) filing exemption is lost, so an Indian return becomes necessary.
- That relief needs TDS at not less than the s.115A rate.
Commonly got wrong
- The DTAA rate on dividends is 10%. It varies by treaty. Quoting one number across countries is wrong, and at least one treaty is worse than domestic law.Check your country's Article 10 rate, commonly 10% or 15%, against 20% plus surcharge and cess under domestic law.