Saudi NRIs: Your DTAA Is Untouched. Four Other Things Aren't.
TL;DR
2.5 million Indians in Saudi Arabia. Your 5% dividend rate and 10% interest rate under the treaty are intact. But what India does with your return, how it reopens it, and when it penalises, all different now.
TrustNRI Editorial · Reviewed by ICAI-registered Chartered Accountants
The cross-country changes, Saudi edition
2.5 million Indians in Saudi Arabia is the largest NRI community anywhere. Your treaty rates — 10% interest (Article 11) and 5% dividends (Article 10), are among the best India has signed with anyone. None of that has changed in 2024-26.
What has changed, and what every Saudi NRI should know about:
**Section 148 reassessment windows** were cut by Finance Act 2024: 3 years for escaped income under ₹50L, 5 years for larger amounts. Old 10-year windows are gone.
**Faceless reassessment is now mandatory** for international tax cases too. The Telangana High Court and the Supreme Court (July 2025) shut the door on Jurisdictional AOs issuing Section 148 notices directly. If you got one, check who issued it before replying.
**Budget 2024's 12.5% LTCG without indexation** applies to every NRI property sale from 23 July 2024. Saudi NRIs selling Indian property get hit by this on the full gain.
**Black Money Act safe harbour** raised from ₹5L to ₹20L for movable foreign assets from 1 October 2024 (Finance (No. 2) Act 2024 amendment), relief for anyone planning to move back.
Saudi-specific: the TRC timing problem is still unsolved
ZATCA (Zakat, Tax and Customs Authority) issues individual TRCs, but only for completed tax years. Saudi Arabia's tax year aligns with the Hijri calendar in some contexts, which creates a mismatch with India's April-March FY.
In practice, most Saudi NRIs file their current-year Indian ITR with a prior-year TRC plus a Form 10F self-declaration. The Indian Income Tax Department has generally accepted this approach, but it's worth having a CA who has actually run this play before.
Nothing about the TRC process changed in 2024-26. What's new is the Form 10F mandatory e-filing, your TRC is now attached to a portal record, not a paper submission.
The deemed-residency trap is still real
India's deemed-residency provision (introduced in Finance Act 2020) still catches NRIs in zero-tax jurisdictions with more than ₹15 lakh of Indian-source income who pay no tax anywhere. Saudi Arabia is a zero personal income tax country for most NRIs.
A valid TRC each year is what keeps you out of deemed-residency and therefore out of the worldwide-income Indian tax net. Don't let the TRC lapse. Don't let Form 10F expire. These are annual rituals.
If your Indian CA hasn't mentioned deemed residency and you earn significant Indian-source income as a Saudi NRI, ask them. It's the single biggest risk for high-earning Gulf NRIs.
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