Moving Back to India? RNOR Keeps Your Foreign Income Tax-Free for Up to 3 Years.
TL;DR
The year you land, India can tax only your Indian income. Your salary, pension and investment returns from abroad stay outside the net. The status is called RNOR, and almost nobody tells returning NRIs to claim it.
By Vipul Sharma, Founder
Reviewed by Preetesh Maloo, Chartered Accountant, NRI Tax Partner
RNOR in one line
RNOR stands for Resident but Not Ordinarily Resident. It is the in-between tax status India gives you for the first few years after you move back from being an NRI.
Here is why it matters. While you are RNOR, India taxes only your Indian income. Your foreign salary, your overseas pension, your US brokerage dividends, your Gulf savings, all of it stays outside the Indian tax net. The one exception is income from a business you control from India or a profession you set up here (the proviso to Section 5(1)).
RNOR usually lasts two to three years, and for most returning NRIs it applies automatically if you claim it. The problem is that nobody prompts you. Your bank re-designates your NRE account to a resident one. Your CA ticks 'Resident' on the return by default. And a two-to-three year window to keep lakhs of foreign income out of Indian tax closes without you ever knowing it was open.
The short version
For up to three years after you return, RNOR means India taxes only your Indian income. Foreign income stays out of the net. You have to claim it on your ITR. No one claims it for you.
Do you qualify? The RNOR test
You are RNOR for a year if you meet either of the two classic conditions (Section 6(6)(a) of the Income-tax Act):
A long-term NRI coming home almost always clears one of these, which is why the first two to three years back usually fall under RNOR.
Two newer routes were added in 2020 for high earners (Section 6(6)(c) and (d)). If you are an Indian citizen or person of Indian origin with more than 15 lakh of Indian income and you spend 120 to 181 days in India, you are a resident but still RNOR. And an Indian citizen with over 15 lakh of Indian income who is not taxed in any other country is a 'deemed resident', also treated as RNOR. Same effect: foreign income stays out.
The Income-tax Act 2025, in force from 1 April 2026, keeps all of this unchanged. Residential status stays in Section 6, and the tests and the 15 lakh figure are the same, so nothing about RNOR changes when the new Act takes over.
Not sure which year your RNOR window closes?
A CA can map your day-count, set your status right on the return, and time your foreign-asset disclosures for the year they actually start.
Senior CA who specialises in NRI tax · we deal with the tax officer, you don't
What it actually saves you
The saving is simply the Indian tax you would have paid on foreign income if you had filed as an ordinary resident.
Say you land back in India with 20 lakh of foreign income in your first year: the last months of a Dubai salary, a UK pension, some US dividends. As an RNOR, the Indian tax on that foreign income is zero. Filed as an ordinary resident, the same 20 lakh gets taxed at slab rates, roughly 2 to 3.7 lakh depending on the regime you choose.
That is the window. It is also the time to restructure: draw down foreign accounts, take pension lump sums, sell overseas holdings, all while the gains sit outside the Indian net.
One year, 20 lakh of foreign income
Filed as RNOR
0 Indian tax
Foreign income is outside the Indian net
Filed as ordinary resident
~2 to 3.7 lakh
Slab rates, new vs old regime
Illustrative. Actual tax depends on your slab and the income mix. India-source income is taxed either way.
The Schedule FA break nobody mentions
Here is the part even good CAs skip. The foreign-asset disclosure rules, Schedule FA in your tax return and the Black Money Act, apply only once you become an ordinary resident. While you are RNOR you do not have to report your foreign bank accounts, brokerage or property in Schedule FA at all. That obligation switches on the year your RNOR status ends.
That gives you a clean runway to organise or wind down foreign holdings before the reporting starts, instead of scrambling in your first year of full disclosure.
One caveat, so you are not caught out later. The 2026 voluntary-disclosure scheme (FAST-DS) can still reach an RNOR for assets that were undisclosed while you were earlier a resident. RNOR protects you going forward. It does not erase an old non-disclosure. If you are sitting on legacy foreign assets, get advice before the RNOR window ends.
Use the runway
No Schedule FA and no Black Money Act reporting while you are RNOR. Organise your foreign accounts before the year full disclosure kicks in.
Your return timeline
RNOR rewards a bit of sequencing. The moves that matter cluster around the months just before and after you land.
What to do, and when
- 3 to 6 months beforeBefore
File any pending DTAA refund claims for your NRI years. Once you are a resident, the NRI treaty benefits stop applying to new income. Past-year claims still stand under Section 119(2)(b) condonation, which runs 5 years back.
- Before you landBefore
Restructure or close foreign accounts that would create Indian tax or reporting complexity later.
- The day you returnOn arrival
RNOR starts. Under FEMA, your NRE account must be re-designated as resident, or the funds moved to an RFC account, immediately on your return, not months later.
- Filing your ITRITR
Explicitly select RNOR as your residential status and keep foreign income out of the taxable computation. Do not let the return default to 'Resident'.
- Years 2 and 3Ongoing
Re-check each year whether you still meet the RNOR test. It is decided year by year, and eventually you become an ordinary resident.
Three traps that cost returning NRIs the most
None of these are exotic. They are the quiet, default-setting mistakes that turn a tax-free window into a tax bill.
Where the money leaks
Filed as a plain resident
The most expensive mistake. The ITR has a residential-status field: Resident, RNOR, Non-Resident. Most CAs pick Resident for anyone living in India. Show them your passport stamps and the day count, and insist on RNOR.
DTAA claims left too late
Claim every DTAA refund for your NRI years before your status changes. After you return, treaty benefits stop applying to new income. Past years are still recoverable through condonation, but only five years back.
NRE account left unconverted
FEMA requires your NRE account to become a resident or RFC account immediately on return. Leaving it as NRE is a breach, not a grace period, whatever your branch tells you.
When to bring in a CA
RNOR is worth real money, and the mistakes are quiet ones: a wrong dropdown on the ITR, a treaty claim filed a year too late, a bank conversion missed. If you have meaningful foreign income or assets in your first years back, this is worth getting right once rather than fixing later.
A CA who does this regularly will set your residential status correctly, keep your foreign income out of the Indian computation while you still qualify, recover your past NRI-year DTAA refunds, and time your Schedule FA disclosures for the year they actually begin. That is the difference between keeping the RNOR window and paying tax you never owed.
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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.
Black Money Act penalty for non-disclosure of foreign assets
Right now: Rs 10 lakh flat, per year of default
Where it works differently
- Aggregate value of foreign assets (OTHER than immovable property) does not exceed Rs 20 lakh at any time in the year
- No penalty under s.42 or s.43.
- De minimis proviso, raised from Rs 5 lakh to Rs 20 lakh by the Finance (No. 2) Act 2024 with effect from 1 October 2024.
- The person is RNOR or non-resident
- Schedule FA does not apply, so no exposure.
- The obligation attaches to a resident and ordinarily resident.
- The foreign asset is immovable property
- The Rs 20 lakh carve-out does NOT apply.
- The proviso expressly excludes immovable property.
Commonly got wrong
- The de minimis threshold is Rs 5 lakh. Raised to Rs 20 lakh from 1 October 2024.Rs 20 lakh, excluding immovable property.
- NRIs must file Schedule FA. It applies to residents and ordinarily residents only.The obligation starts when you become ordinarily resident.
Schedule FA reporting period
Right now: The CALENDAR year ending during the relevant financial year, not the Indian financial year
Where it works differently
- Filing for FY 2025-26
- Schedule FA covers 1 January to 31 December 2025, a nine-month offset from the Indian tax year.
- The schedule is aligned to foreign reporting years so that CRS and FATCA data reconcile.
- An asset was held for even one day in that calendar year
- It is reportable. Closing the account before 31 March does not remove the obligation.
- 'At any time during' the period.
- The taxpayer is RNOR or non-resident
- Schedule FA does not apply at all.
- The duty attaches to a resident and ordinarily resident.
Commonly got wrong
- Schedule FA covers the Indian financial year. It covers the calendar year ending within that financial year.Schedule FA in the FY 2025-26 return covers 1 January to 31 December 2025, the calendar year, not the Indian financial year.
Primary residence test: days in India
Right now: 182 days
Where it works differently
- The person is an Indian citizen leaving India for employment abroad, or as a crew member of an Indian ship
- Only the 182-day test applies. The 60-day secondary test is disabled.
- Explanation 1(a) to s.6(1)
- Counting days
- The day of arrival AND the day of departure both count as days in India.
- Settled administrative practice; partial days count as whole days.
- The financial year straddles a move
- Residence is decided for the WHOLE financial year, not from the date of the move. India has no split-year concept, unlike the UK.
- s.6 is a full-year test.
Commonly got wrong
- You become an NRI the day you leave India. True for FEMA, false for income tax. Under FEMA residence changes on departure with intent; under the Income-tax Act it is a full-year day count.Name which law you mean. Say 'non-resident under FEMA from the day you leave' or 'non-resident for income tax if you are in India under 182 days in that financial year'.
- India has split-year treatment. It does not. Only the treaty tie-breaker resolves a dual-residence year.Point to Article 4 of the relevant DTAA.
Deemed residence: Indian income threshold
Right now: Rs 15 lakh
Where it works differently
- The person is liable to tax in any other country
- s.6(1A) does not apply at all.
- The provision targets stateless-for-tax individuals only.
- s.6(1A) applies
- The person is RNOR, not ordinarily resident. Foreign income is not taxed in India.
- s.6(6)(d).
Commonly got wrong
- Gulf NRIs earning over Rs 15 lakh in India become fully taxable on worldwide income. They become RNOR, so foreign income remains outside the Indian net.Say 'deemed resident but RNOR, Indian income only'.