Dublin to Bengaluru: The India-Side Changes of 2024-26 for Ireland NRIs
TL;DR
Ireland's Indian tech community is growing fast. The India-Ireland DTAA is solid. But four India-side changes in the last 24 months affect how you file, respond to notices, and plan property sales.
TrustNRI Editorial · Reviewed by ICAI-registered Chartered Accountants
What's stable, what's changed
The India-Ireland DTAA caps interest at 10% (Article 11) and dividends at 10% (Article 10). These rates haven't moved. If your Dublin-based Indian salary is flowing into NRO deposits and Indian mutual funds, the treaty mechanics are unchanged.
Four India-side changes in 2024-26 that DO affect Ireland NRIs:
1. **Finance Act 2024 Section 148 rewrite.** Reassessment time limit cut to 3 years (5 if escaped income above ₹50L). 10-year window is gone.
2. **Faceless mandate enforced.** Telangana HC and Supreme Court confirmed Section 148 notices must go through NFAC. JAO direct issuance is void. Ireland NRIs in the International Taxation range are directly affected.
3. **Budget 2024 LTCG overhaul.** 12.5% flat on NRI property sales, no indexation, from 23 July 2024.
4. **Black Money Act safe harbour.** ₹5L → ₹20L for movable foreign assets, Finance (No. 2) Act 2024 amendment effective 1 October 2024.
Revenue Commissioners TRC: still the gold standard
Ireland's Revenue Commissioners issue TRCs via their online MyEnquiries portal. The process is fast (1-2 weeks), free, and paperless. Your certificate is valid for the Irish tax year.
When filing your Indian ITR, the TRC plus Form 10F via the Indian e-filing portal gets you the 10% interest and 10% dividend rates. This is uncontested, every-year recovery.
Ireland's remittance-basis rules for non-domiciled residents also affect some Indian-origin tax residents, similar to the old UK non-dom regime. Irish non-dom is still in force (unlike the UK, which abolished theirs in April 2025).
For Ireland NRIs planning an Indian property sale
The Budget 2024 rule hits hardest on mid-held Indian properties (5-15 years). NRIs pay 12.5% flat on LTCG from 23 July 2024 — there is no indexation election. The 20%-with-indexation option is available only to resident individuals/HUFs.
For NRIs, apply for a Form 13 Section 197 lower-TDS certificate 2 months before the sale. Otherwise the buyer deducts 12.5% on the full sale price, not the gain, and you wait 6-12 months for the refund.
Our tax representation team handles the Form 13 process under Section 288 Authorized Representative, no need to fly to India for the AO hearing.
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