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