London, Manchester, Birmingham: India's 2024-26 changes plus FIG

The India-UK DTAA, signed in 1993, caps interest tax at 15% under Article 11 and dividends at 10 to 15% under Article 10. None of those rates moved in 2024-26.

Default Indian TDS for non-residents under Section 195 is 30%. Without TRC + Form 10F on file, your Indian bank deducts at 30% even though the treaty entitles you to 15%.

For a London-based banker with a ₹40 lakh NRO FD at 7%, that's ₹2.8 lakh annual interest. At 30% default: ₹84,000 deducted. At 15% treaty: ₹42,000. Annual gap: ₹42,000. Over 6 years: ₹2.52 lakh recoverable plus Section 244A interest at 6% simple per delayed year.

The gap is real. The recovery is a paperwork exercise once you know the steps.

Section 148 reopening cut to 3 years (small additions) or 5 years (large additions ≥ ₹50 lakh). From 1 September 2024.

Section 148A faceless mandate. The Supreme Court ruling of July 2025 confirmed JAO-issued Section 148 notices are void. Faceless e-Verification under Section 144B is the only valid route.

Budget 2024 LTCG. NRI property sales taxed at 12.5% flat without indexation, or 20% with indexation, whichever yields the lower tax. Effective 23 July 2024.

Black Money Act 2015 safe harbour raised to ₹20 lakh for movable foreign assets, September 2025. Your ISA in HSBC, your premium bonds, your Vanguard UK funds, all under ₹20 lakh equivalent are no longer reportable on Schedule FA.

The UK abolished the non-dom regime on 6 April 2025. The new Foreign Income and Gains regime replaced remittance basis taxation.

Key shifts for British Indians:

For your first 4 years of UK tax residence, foreign income and gains are exempt from UK tax under FIG, regardless of remittance.

After 4 years, full worldwide taxation applies, no more remittance-basis shielding.

NRE interest, previously remittance-basis-exempt, is now taxable in the UK once the 4-year FIG window closes.

Double tax relief under the India-UK DTAA continues, so you claim foreign tax credit in the UK for Indian TDS already paid.

If you arrived in the UK before 6 April 2021, you've already exited any FIG window. Your worldwide income, including NRE interest, is fully UK-taxable from FY 2025-26 onwards. Plan with a UK-side CA who knows the FIG mechanics.

British Indians get TRCs from HMRC via the Government Gateway portal at gov.uk. Application is free, online, and quick.

Login with your Government Gateway ID. Apply for a Certificate of Residence under the relevant DTAA. Specify the period (calendar year or financial year), the income type, and the Indian counterparty if known.

Processing: 2 to 4 weeks for standard cases. HMRC may ask for proof of UK tax residency (P60, employment record, NI contributions). Most British Indians clear this in one round.

The certificate covers the period requested. Most submit annually for the calendar year.

Form 10F online filing on incometax.gov.in takes 5 minutes once the HMRC TRC is in hand. Upload as PDF. Submit. Acknowledgment goes to your Indian bank to apply the 15% rate going forward.

Section 119(2)(b) gives 6 years of rolling lookback. Every April, the oldest year drops out.

A London NRI with a ₹35 lakh NRO FD at 7% over 6 years paid ₹4.41 lakh in default 30% TDS. At the 15% treaty rate, it should have been ₹2.21 lakh. Gap: ₹2.20 lakh.

Add Section 244A interest at 6% simple per delayed year. The oldest year carries roughly 30% interest. Total recovery range: ₹2.55 to ₹2.75 lakh on a clean 6-year claim.

The recovered Indian TDS reduces your foreign tax credit on the UK side. If you've been claiming UK FTC at 15% on the NRO interest, the additional Indian recovery reduces that FTC base. The net economic gain is roughly 60 to 70% of the headline India recovery, which is still substantial.

We coordinate with UK-side accountants when the FTC math gets complex.

Upload your 26AS or AIS. We read every TDS line, apply the 15% Article 11 treaty rate, and quote the recoverable amount in pounds.

If you want us to take it on, a UK-specialist CA files the current-year ITR at 15% and a Section 119(2)(b) condonation for past years. We handle AO correspondence under Section 288 so you don't fly to Mumbai.

We charge 15% of what we recover. Zero if we recover zero. Form 10F renewal after that is ₹799 a year on a flat fee.

If you'd rather book a free CA appointment first and ask FIG-specific questions, that's free, no card, no commitment, 15 minutes.

British Indians have two clocks running simultaneously. India-side, the 6-year rolling Section 119(2)(b) window for past-year recovery. UK-side, the 4-year FIG window for new arrivals or the worldwide-tax regime for everyone past that.

The interaction matters. If you're inside your FIG window and Indian TDS was overdeducted at 30%, the recovery in India is straightforward. The recovered amount has no UK-side tax consequence because foreign income is FIG-exempt anyway.

If you're past your FIG window and on worldwide UK taxation, the recovered Indian TDS reduces your UK foreign tax credit. Net economic gain is roughly 60 to 70% of the headline India recovery.

For British Indians who arrived between 2021 and 2025, you're in a transition zone, partial FIG protection on the way out. Plan with a UK-side accountant before filing the Indian condonation, the timing of when the refund hits the UK return matters. We coordinate with both sides on request.

Q: I just moved to the UK in 2025. Does FIG cover me?

A: Yes if you meet the 4-year window criteria (not UK tax-resident in any of the prior 10 tax years). Your first 4 years of UK residence get foreign income exemption. After 4 years, worldwide taxation kicks in. Plan your remittance pattern around the 4-year mark.

Q: My NRE FD interest was always tax-free. Does that change post-FIG?

A: NRE interest is exempt under Section 10(4)(ii) on the Indian side, that hasn't changed. On the UK side, post-FIG (or after your 4-year window), it's taxable as foreign interest at your UK marginal rate. Since NRE has zero Indian tax, no foreign tax credit is available on the UK return.

Q: Is the HMRC TRC automatic or do I have to apply each year?

A: You apply each year. HMRC doesn't issue rolling TRCs. Set a calendar reminder for January or February each year so the TRC lands before your Indian Form 10F refile in April.

Q: I'm a UK citizen who's now back in India. Am I still British for treaty purposes?

A: Treaty residency follows tax residency, not citizenship. Once you're back in India and meet the 182-day rule under Section 6, you're an Indian tax resident. Tie-breaker rules apply if both countries claim you. Book free CA appointment to walk through the specifics.