Mutual Fund Redemption TDS

Nepal

Article 13(6), fund/ETF units only: the residual clause is residence-only, so India has no right to tax the gain at all, Nepal taxes it instead. Listed EQUITY SHARES are the opposite, Article 13(5) keeps them source-taxed in India regardless, same as with no treaty

Cyprus

Article 13(6), fund/ETF units: residence-only, India has no right to tax the gain at all. Listed EQUITY SHARES acquired ON OR BEFORE 31 March 2017 are grandfathered the same way (Article 13(4)); shares bought after that date stay source-taxed in India at the standard rate, the treaty gives them no relief. Either way, Cyprus's own domestic law exempts securities gains for every resident regardless of non-dom status, so anything India doesn't tax is genuinely tax-free, not just deferred. Caveat: the treaty is MLI-covered, so its Principal Purpose Test can deny the benefit where the Cyprus move looks structured mainly to obtain it, this needs to be a genuine relocation, not a paper one

Malta

Article 13(5), fund/ETF units: residence-only, India has no right to tax the gain at all, and Malta's own law never taxes a foreign capital gain regardless of non-dom status, so the gain is genuinely tax-free both sides. Listed EQUITY SHARES stay source-taxed in India under Article 13(4), the treaty gives them no relief. A layered trap on top of that: the MLI's Article 9(4) 'property-rich company' rule also applies to this treaty (Malta opted OUT of the MLI's general Article 9(1) but specifically OPTED IN to 9(4)), so shares in an Indian company that derived more than 50% of its value from Indian immovable property at any point in the preceding 365 days stay source-taxable in India even where the ordinary share rule might otherwise have been read more narrowly. This property-rich look-through targets company SHARES specifically, an Indian mutual fund unit is a trust interest, not a company share, so it isn't caught by it. Separately, the treaty is MLI Principal-Purpose-Test covered, so a Malta move set up mainly to obtain the exemption can have it denied, the residence has to be genuine

Russia

Article 13's residual paragraph, 'gains from the alienation of any property other than that mentioned in paragraphs 1-4', is residence-only, and an Indian mutual fund or ETF unit falls there, so India has no right to tax the gain at all, Russia taxes it instead at its own slab rate. Listed EQUITY SHARES sit in the earlier, specific paragraph ('gains from the alienation of shares of a company... may be taxed in that State'), so they stay source-taxed in India regardless, the treaty gives them no relief

Mexico

Article 13(6), fund/ETF units only: read directly from the treaty, the residual clause ('gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5') is residence-only, so India has no right to tax the unit gain at all, Mexico taxes it instead. Listed EQUITY SHARES sit in the separate Article 13(5) ('gains from the alienation of shares... may be taxed in that State'), source-taxed in India regardless, same as with no treaty. A share in a company whose value is principally Indian immovable property falls in the stricter Article 13(4) instead, also source-taxed

Ukraine

Article 13(6), ordinary fund/ETF units only: gains on property not covered by paragraphs 1 to 5 are taxable only in the alienator's state of residence, provided those gains are subject to tax there. Two conditions: the gain must be subject to Ukrainian tax (Ukraine taxes investment profit), and the units must fall outside the MLI property-rich rule in Article 13(4) (a trust or fund deriving over 50% of its value from Indian immovable property in the 365 days before sale is source-taxed). Meet both and India has no right to tax the unit gain. Listed EQUITY SHARES are the opposite: Article 13(5) lets India tax gains on shares of an Indian company, so they stay taxed in India at the standard rate.

Taiwan

Article 13(6), fund/ETF units only: the residual clause ('gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5') is residence-only, and Article 13(5) reaches only shares in a company, so India has no right to tax a mutual fund or ETF unit gain. Listed EQUITY SHARES of Indian companies stay taxable in India at 12.5% under Article 13(5) (and 13(4) for property-rich shares), the agreement gives them no relief.

Lithuania

Article 13(5), fund/ETF units: the residual clause makes gains on 'any property other than' that in paragraphs 1 to 4 taxable only in the residence state. An Indian mutual fund unit is a trust interest, not a company share, so India has no right to tax the gain and Lithuania taxes it instead. Listed EQUITY SHARES fall under Article 13(4) ('shares in a company which is a resident of a Contracting State may be taxed in that State') and stay taxable in India at 12.5%, with no treaty relief. A Mumbai ITAT ruling (Anushka Sanjay Shah, March 2025) took the same view of fund units under the Singapore treaty. The treaty is MLI-covered, so the Principal Purpose Test can deny the benefit where the arrangement is mainly tax-driven.

Czech Republic

Article 13(6), mutual fund and ETF units: the residual clause ('gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5') is residence-only, and an Indian MF unit is a trust unit, not a company share, so India has no right to tax the gain and Czechia taxes it instead. Listed and unlisted Indian SHARES are the opposite: Article 13(5) ('shares ... in a company which is a resident of a Contracting State may be taxed in that State') keeps them taxable in India at 12.5%, and Article 13(4) does the same for property-rich companies. Where the Czech 3-year holding exemption applies to shares, there is no Czech tax to credit the Indian tax against.

Romania

Article 13(5), fund/ETF units: the residual clause ('gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 4') is residence-only, and an Indian mutual fund unit is a trust interest, not a company share, so India has no right to tax the gain at all; Romania taxes it instead at 16%. Listed EQUITY SHARES sit in Article 13(4) ('gains from the alienation of shares in a company which is a resident of a Contracting State may be taxed in that State'), so they stay source-taxed in India at 12.5%, and Romania credits that tax up to its own.

Bulgaria

Article 14(6), fund/ETF units only: Article 14(5) lets India tax gains on 'shares' of a company resident in India, but an Indian mutual fund is a trust, not a company, so a unit gain falls into Article 14(6), 'any property other than' paragraphs 1 to 5, which is taxable only in the residence state. India has no right to tax it and Bulgaria taxes it instead, at 10%. The Mumbai ITAT read the same residual clause this way under the India-Singapore treaty (Anushaka Sanjay Shah, 2025). Two limits: listed Indian EQUITY SHARES stay taxable in India at 12.5% under Article 14(5), and an Indian citizen merely living in Bulgaria is not a treaty resident under Article 4(1)(b), so their unit gains stay at 12.5% too. The 0% is for a Bulgarian national only.

Hungary

Article 13(6), fund/ETF units only: 13(5) covers only shares in a company, and an Indian mutual fund unit is a trust unit, so it falls in the residual clause ('gains from the alienation of any property other than that referred to in the preceding paragraphs'), which is residence-only. India has no right to tax the unit gain, Hungary taxes it instead. Listed EQUITY SHARES of an Indian company stay source-taxed in India at 12.5% under Article 13(5), and Hungary then exempts that gain under Article 23(1)(a).

Kazakhstan

Article 13(6), fund/ETF units only: gains on 'any property other than that referred to in the preceding paragraphs' are taxable only in the country of residence, so India has no right to tax an Indian mutual fund or ETF unit gain and Kazakhstan taxes it instead. Listed EQUITY SHARES sit in Article 13(5) ('may be taxed in that State') and stay taxed in India regardless; shares in a property-rich company fall in Article 13(4), also taxed in India

Georgia

Article 13(6), fund and ETF units only: gains on property not covered by paragraphs 1 to 5 are taxable only in the country of residence, so India has no right to tax a Georgia resident's Indian mutual fund or ETF unit gain. Indian SHARES stay taxable in India at 12.5% under Article 13(5), and shares of a company whose property is mainly Indian immovable property fall in Article 13(4), also taxable in India. Benefits are subject to Article 30 as modified by MLI Article 7(1): the treaty's own main-purpose test plus the MLI principal purpose test, which denies a benefit where getting it was one of the principal purposes of an arrangement, unless granting it matches the object and purpose of the provision (India: from 1 April 2020)

Slovakia

Article 13(6), mutual fund and ETF units: gains on property not covered by paragraphs 1 to 5 are taxable only in the residence state. Article 13(5) covers only 'shares ... in a company', and an Indian MF unit is a trust unit, so India has no right to tax the unit gain and Slovakia taxes it instead. Indian SHARES stay taxable in India at 12.5% under Article 13(5). Article 13(4) was replaced by MLI Article 9(4): shares or trust interests deriving over 50% of their value from Indian property in the 365 days before sale (for example REIT units) stay taxable in India. The MLI principal purpose test also applies.

Estonia

Article 13(6), fund/ETF units: gains on 'any property other than' that in paragraphs 1 to 5 are taxable only in the residence state. An Indian mutual fund unit is a trust interest, not a company share, so India has no right to tax the gain; Estonia taxes it at 22% after deductions and the basic exemption. Listed EQUITY SHARES fall under Article 13(5) and stay taxable in India at 12.5%, with no treaty relief; once India has actually taxed the gain, Article 23(2)(a) exempts it in Estonia. Article 13(2), as replaced by MLI Article 9(4), lets India tax shares and comparable interests, such as partnership or trust interests, that derived more than 50% of their value from Indian immovable property at any time in the 365 days before the sale. So a property-rich fund unit stays taxable in India; ordinary mutual fund units do not. MLI Article 7(1) (Principal Purpose Test) denies a treaty benefit where obtaining it was one of the principal purposes of an arrangement.

Uzbekistan

Article 14(6), fund units only: gains on any property not covered by paragraphs 1 to 5 are 'taxable only' in the country of residence, so India has no right to tax an Indian mutual fund or ETF unit gain and Uzbekistan taxes it instead. Indian SHARES stay taxable in India at 12.5%: Article 14(5) lets India tax gains on shares of an Indian company, and Article 14(4) covers shares of property-rich companies. Benefits depend on the anti-abuse rule in Article 28B

Belarus

Article 13(6), fund/ETF units only: gains on property other than that in paragraphs 1 to 5 are taxable only in the country of residence, so India has no right to tax an Indian mutual fund or ETF unit gain and Belarus taxes it instead. Listed Indian SHARES fall under Article 13(5) ('may be taxed in that State') and stay taxable in India at 12.5%; shares in a property-rich company fall under Article 13(4), also taxable in India

Albania

Fund and ETF units only. Article 13(4) lets India tax gains on 'shares in a company' resident in India, so listed Indian SHARES stay taxable in India at 12.5%. An Indian mutual fund is a trust, not a company, so a unit gain falls into Article 13(5), gains on any other property, taxable only in the residence state. India has no right to tax it, and Albania taxes it at 15%. The treaty has no subject-to-tax condition, and Albania did not opt into the MLI property-rich shares rule (MLI Article 9(4)), so that rule does not apply here.

Serbia

Article 14(6), fund units only: Article 14(5) lets India tax gains on shares of an Indian company, but an Indian mutual fund is a trust, not a company. A unit gain falls in 14(6), 'any property other than' paragraphs 1 to 5, taxable only in Serbia, which charges 15%. Listed Indian EQUITY SHARES stay taxable in India at 12.5% under 14(5). Limit: MLI Article 9(4) replaced 14(4), so India may tax units of a trust that drew more than 50% of their value from Indian immovable property at any time in the 365 days before sale.

Bhutan

Article 13(6), fund/ETF units only: gains on property not covered by paragraphs 1 to 5 are taxable only in the country of residence, so India has no right to tax a Bhutan resident's gain on Indian mutual fund or ETF units. Listed EQUITY SHARES sit in Article 13(5) and stay taxable in India at 12.5%; shares in a property-rich company fall in Article 13(4), also taxed in India. Article 27 denies benefits to arrangements whose main purpose is the treaty benefit

Kyrgyzstan

Article 13(6), fund and ETF units only: gains on 'any property other than' that in paragraphs 1 to 5 are taxable only in the alienator's residence state, so India has no right to tax an Indian mutual fund or ETF unit gain. Indian SHARES stay taxable in India at 12.5% under Article 13(5) ('may be taxed in that State'), and shares in property-rich companies under Article 13(4). The treaty has no principal purpose test or limitation of benefits clause, but the Article 4(1) residence test still applies

Iceland

Article 13(6), fund/ETF units only: Article 13(5) covers only shares in a company, and an Indian mutual fund unit is a trust unit, so it falls in the residual clause ('gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5'), which is taxable only in the residence state. India has no right to tax the unit gain, and Iceland taxes it as capital income at 22%. Listed EQUITY SHARES of an Indian company stay taxable in India at 12.5% under Article 13(5), and shares in a property-rich company under Article 13(4). The MLI did not change Article 13, but it added a Principal Purpose Test, so the Iceland residence must be genuine.

Latvia

Article 13(6), fund/ETF units: gains on any property other than that in paragraphs 1 to 5 are taxable only in the residence state. An Indian mutual fund unit is a trust interest, not a company share, so India has no right to tax the gain and Latvia taxes it at 25.5%. Listed EQUITY SHARES fall under Article 13(5) ('shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State') and stay taxable in India at 12.5%, with no treaty relief; once India has taxed the gain, Article 23(2)(a) exempts it in Latvia. Article 13(4) lets India tax shares of a company whose property is principally Indian immovable property. The MLI did not add the Article 9(4) 365-day test to this treaty. MLI Article 7(1) (Principal Purpose Test) replaces Article 28 and denies a benefit where obtaining it was one of the principal purposes of an arrangement.

Slovenia

Article 13(6), mutual fund and ETF units: gains on property not covered by paragraphs 1 to 5 are taxable only in the residence state. Article 13(5) covers only 'shares' in a company, and an Indian MF unit is a trust unit, so India has no right to tax the unit gain and Slovenia taxes it instead (25%, falling to 20% after 5 years, 15% after 10 and 0% after 15). Indian SHARES stay taxable in India at 12.5% under Article 13(5). Article 13(4) was replaced by MLI Article 9(4): shares or trust interests deriving over 50% of their value from Indian property in the 365 days before sale (for example REIT units) stay taxable in India. The MLI principal purpose test also applies.

Croatia

Article 13(6), mutual fund and ETF units: gains on property not covered by paragraphs 1 to 5 are taxable only in the residence state. Article 13(5) covers only 'shares ... in a company', and an Indian MF unit is a trust unit, so India has no right to tax the unit gain. Indian SHARES stay taxable in India at 12.5% under Article 13(5). Article 13(4) is replaced by MLI Article 9(4): shares or trust interests deriving over 50% of their value from Indian property in the 365 days before sale (for example REIT units) stay taxable in India. The MLI principal purpose test also applies. Croatia taxes gains on financial assets, including fund units, at 12% only if sold within two years of purchase.

Armenia

Article 13(6), fund and ETF units only: gains on any property not covered by paragraphs 1 to 5 are taxable only in the country of residence, so India has no right to tax an Armenia resident's Indian mutual fund or ETF unit gain. Indian SHARES stay taxable in India at 12.5% under Article 13(5). Article 13(4), as modified by MLI Article 9(4) (both countries opted in), lets India tax shares or comparable interests, such as interests in a partnership or trust, that derived more than 50% of their value from Indian immovable property at any time in the 365 days before the sale. So units of a property-heavy fund or trust, such as a REIT, can stay taxable in India. Benefits are subject to Article 28 (limitation of benefits; individuals are qualified persons) and the MLI principal purpose test (MLI Article 7(1))

North Macedonia

Fund units only. Article 13(5) lets India tax gains on 'shares' in an Indian company, so listed Indian SHARES stay taxable in India at 12.5%. An Indian mutual fund is a trust, not a company, so a unit gain falls in Article 13(6), any other property, taxable only in the residence state. Limit: both countries chose MLI Article 9(4), which lets India tax interests in a trust that drew more than 50% of their value from Indian immovable property in the 365 days before sale (for example REIT units).

Montenegro

Article 14(6), fund units only: Article 14(5) lets India tax gains on shares of an Indian company, but an Indian mutual fund is a trust, not a company. A unit gain falls in 14(6), 'any property other than' paragraphs 1 to 5, taxable only in Montenegro, which charges 15%. Listed Indian EQUITY SHARES stay taxable in India at 12.5% under 14(5). Article 14(4) (property-rich companies) covers only company shares, and MLI Article 9(4) does not extend it here because the MLI does not cover this treaty.

Myanmar

Article 13(6), fund and ETF units only: gains on property not covered by paragraphs 1 to 5 are taxable only in the country of residence, so India cannot tax a Myanmar resident's gain on Indian mutual fund or ETF units. Indian equity SHARES fall under Article 13(5) and stay taxable in India at 12.5%. Shares in a company whose assets are mainly Indian immovable property fall under Article 13(4), also taxed in India. Article 27 denies benefits to arrangements whose main purpose is the treaty benefit

Mongolia

Article 13(6), fund and ETF units only: gains on property not covered by paragraphs 1 to 5 are taxable only in the seller's residence state, so India cannot tax gains on ordinary Indian mutual fund or exchange-traded fund (ETF) units. Exception: MLI Article 9(4), chosen by both India and Mongolia, lets India tax gains on shares or comparable interests, including trust units, that derived more than 50% of their value from Indian immovable property at any time in the 365 days before the sale, so property-heavy units can stay taxable in India. Indian SHARES stay taxable in India at 12.5% under Article 13(5) ('shares ... in a company which is a resident'), and shares in property-rich companies under Article 13(4), as tightened by MLI Article 9(4). The MLI principal purpose test also applies

Tajikistan

Article 13(5) covers mutual fund and ETF units: gains on any property not covered by paragraphs 1 to 4 are taxable only in the alienator's residence state, so India has no right to tax them. Indian SHARES stay taxable in India at 12.5% under Article 13(4), which covers shares in a company resident in India, with no holding threshold. The treaty has no separate clause for shares in property-rich companies. Article 28(6) denies treaty benefits to anyone whose affairs were arranged mainly to avoid tax

Morocco

Article 13(6), fund and ETF units only: gains on property not covered by paragraphs 1 to 5 are taxable only in the country of residence, so India has no right to tax a Morocco resident's Indian mutual fund or ETF unit gain. Indian SHARES stay taxable in India at 12.5% under Article 13(5), and shares of a company whose property is mainly Indian immovable property are taxable in India under Article 13(4). Morocco has signed but not ratified the MLI, so the MLI's property-rich rule (Article 9(4)) and principal purpose test do not apply to this treaty

Colombia

Article 13(6), fund and ETF units only: gains on any property not covered by paragraphs 1 to 5 are taxable only in the country of residence, so India has no right to tax a Colombia resident's gain on Indian mutual fund or ETF units. Indian SHARES stay taxable in India at 12.5% under Article 13(5). Shares of a company whose assets are more than 50% Indian immovable property fall under Article 13(4) and also stay taxable in India. Colombia has not ratified the MLI, so the MLI Article 9(4) extension to trust interests does not apply; get a CA to confirm the position for REIT and InvIT units. Colombia taxes the gain instead

Chile

Article 13(6), ordinary mutual fund and ETF units: gains on property not covered by paragraphs 1 to 5 are taxable only in the residence state. Article 13(5) covers 'shares or other rights representing the capital of a company' resident in India, and an ordinary Indian MF unit is a trust unit, not a company capital right, so India has no right to tax the unit gain and Chile taxes it instead. Indian shares and other company capital rights stay taxable in India at 12.5% under Article 13(5). Article 13(4) keeps India's right over shares or trust interests that drew more than 50% of their value from Indian immovable property in the 365 days before sale (for example REIT units). The 0% is also subject to Article 28: where Chile does not effectively tax the gain, including foreign income exempt in a newcomer's first three years, Article 28(11) restores Indian tax at 12.5%; the principal purpose test in Article 28(9) also applies.

Trinidad & Tobago

Article 13(6), mutual fund and ETF units: gains from property not covered by paragraphs 1 to 5 are taxable only in the residence State, so India has no right to tax a Trinidad and Tobago resident's gain on fund units. There is no subject-to-tax condition, and the MLI does not apply because Trinidad and Tobago has not signed it. Indian SHARES are the opposite: Article 13(5) lets India tax gains on shares of an Indian company, and 13(4) covers property-rich companies, so shares stay taxable in India at 12.5%. Trinidad and Tobago taxes only gains on assets held 12 months or less.

Zambia

Article 13(4): gains on any property other than immovable property (13(1)), business assets of a permanent establishment (13(2)) and ships or aircraft (13(3)) are taxable only in the country of residence. This 1981 treaty has no separate paragraph for shares, so unlike most Indian treaties it covers listed Indian SHARES as well as mutual fund and ETF units. Zambia has no capital gains tax and does not tax foreign gains. There is no subject-to-tax condition and Zambia has not signed the MLI (Multilateral Instrument), so no principal purpose test applies, but India's domestic anti-avoidance rules still can. Expect fund houses to deduct TDS unless you file Form 41 with a TRC

Mozambique

Article 13(5): gains on shares of an Indian company may be taxed in India, and 13(4) covers companies whose property is principally Indian immovable property. So Indian SHARES stay taxable at 12.5%. Mutual fund units are not shares of a company: they fall under the residual Article 13(6), which makes other gains taxable only in the residence state. India has no right to tax them, and Mozambique taxes the gain at its own 10% to 32% capital gains rates. Article 28 denies treaty benefits where obtaining them was a primary purpose of the arrangement. The MLI does not apply: Mozambique has not signed it.

Botswana

Article 14(6), fund and ETF units only: gains on property not covered by paragraphs 1 to 5 are taxable only in the seller's residence state, so India cannot tax gains on ordinary Indian mutual fund or exchange-traded fund (ETF) units of a qualifying Botswana treaty resident. Where treaty residence fails (see Article 4(1) under challenges), India's 12.5% applies. Indian SHARES stay taxable in India at 12.5% under Article 14(5) ('shares ... in a company which is a resident'), and shares in companies whose property is principally Indian immovable property under Article 14(4). Botswana has not signed the MLI, so no principal purpose test or MLI property-rich rule changes this treaty

Uruguay

Indian SHARES stay taxable in India at 12.5% under Article 13(5). Article 13(4), as modified by MLI Article 9(4), also lets India tax gains on shares or comparable interests, including trust interests, that drew more than 50% of their value from Indian immovable property at any time in the 365 days before the sale. Ordinary mutual fund units are not shares of a company, so they fall under the residual Article 13(6): taxable only in Uruguay. One condition: Protocol paragraph IV lets India keep the right to tax where the particular gain is not taxable in Uruguay. Uruguay has taxed residents' foreign capital gains since 1 January 2026, at 12% or at a reduced 6% or 7% under special regimes, so the 0% applies to such gains from 2026. Where the gain is not taxable in Uruguay (before 2026, or under a full exemption), India keeps 12.5%.

Iran

Article 14. Gains on Indian SHARES stay taxable in India at 12.5% under Article 14(5), which covers shares of an Indian company, and Article 14(4) keeps India's right over shares of a property-rich company. Mutual fund units are not shares of a company, so they fall under Article 14(6): taxable only in the residence state. There is no subject-to-tax condition, but Article 28 denies the benefit where obtaining it was one of the principal purposes of an arrangement

Ethiopia

Article 13(5): gains on shares of an Indian company may be taxed in India, so Indian SHARES stay taxable at 12.5%. Article 13(4) adds the same for shares of companies whose property is mainly Indian real estate. Mutual fund and ETF units are not shares of a company, so they fall under the residual Article 13(6) and are taxable only in Ethiopia. There is no subject-to-tax condition. Ethiopia has not signed the MLI (Multilateral Instrument), but the treaty's own Article 28 denies benefits where obtaining them was a main purpose, and keeps India's domestic anti-avoidance rules. Expect fund houses to deduct TDS unless you file Form 41 with a TRC

Namibia

Article 13(6), fund and ETF units only: gains on property not covered by paragraphs 1 to 5 are taxable only in the alienator's residence state, so India cannot tax a Namibia resident's gain on ordinary Indian mutual fund or ETF units. Indian SHARES stay taxable in India at 12.5% under Article 13(5), and shares of property-rich companies under Article 13(4). Namibia does not tax the gain because it has no capital gains tax at all, a general exemption rather than one for foreign-source income, so Article 24(1) (limitation of benefits) should not apply. India could still argue it does, so keep the treaty residency certificate and Form 41 on file. Namibia has not ratified the MLI, so no principal purpose test applies

Syria

Article 13(4) lets India tax gains on shares of an Indian company, so Indian SHARES stay taxable in India at 12.5%. Mutual fund units are not shares of a company. They fall under Article 13(5), which makes gains on any other property taxable only in the residence state, with no subject-to-tax condition. Syria has not signed the MLI, so no MLI property-rich rule applies. Whether Syria taxes the gain is for a Syrian adviser to confirm

Sudan

Article 13(5): gains on shares of an Indian company may be taxed in India, so Indian SHARES stay taxable at 12.5%. Article 13(6) makes gains on any other property taxable only in the seller's country of residence, and Indian mutual fund units are not shares of a company, so MF units fall under that paragraph. Article 13(4) separately lets India tax shares of a company whose property is mainly Indian immovable property. Sudan has not signed the MLI (Multilateral Instrument), so the treaty text stands as written.

Turkmenistan

Article 13(5) lets India tax gains on shares of any Indian company, with no holding threshold, so Indian SHARES stay taxable in India at 12.5% (13(4) covers property-rich companies). Mutual fund units are not shares of a company, so they fall under Article 13(6): gains on other property are taxable only in the residence state. Turkmenistan can tax those gains, because its exemption for sales of personal property excludes shares and other securities (Tax Code Article 187(1)(j)). The treaty has no subject-to-tax condition on 13(6)