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Cross-border capital gains

Are your Indian share and mutual fund gains taxable in India if you live in Spain?

You are a Spanish tax resident selling Indian listed shares or redeeming Indian mutual funds, and you want to know whether India can tax the gain at all when your stake in the company is small.

You are a Spanish tax resident selling Indian listed shares or redeeming Indian mutual fund units, and you have been told India taxes the gain. On an ordinary portfolio this treaty says otherwise: both the shares and the units are taxable only in Spain. The risk here is not overpaying by a little, it is paying Indian tax you never owed on the whole gain, because the exemption has to be claimed and nobody claims it for you.
Last reviewed: 6 August 20266 min readReviewed by Preetesh Maloo, CA

The short answer

India taxes neither, on an ordinary portfolio, while you are a Spanish tax resident. Under the India-Spain treaty, Article 14(5) only lets India tax a share gain where your holding is at least 10 per cent of the company, and the residual clause, Article 14(6), is residence-only. So a private holding below 10% of an Indian company is taxable only in Spain, and a mutual fund unit, being a trust unit and not a company share, falls in that residence-only residual clause too. India keeps the right in two cases: a stake of 10% or more, and a company or fund whose value comes mainly from Indian immovable property. Everything else in a normal portfolio carries no Indian tax. This is not automatic, though. India withholds first and asks later, so you claim it with a Tax Residency Certificate and Form 10F, now Form 41, and reclaim anything already deducted through an Indian return.

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Are your Indian share and mutual fund gains taxable in India if you live in Spain?

On an ordinary portfolio, no, on either. Most treaties let India tax a non-resident's Indian share gains outright, and this one does not. Article 14 of the India-Spain treaty only reaches a stake of 10% or more, so a private investor holding a slice of an Indian listed company sits below the line and the gain is taxable only in Spain. Your fund units get there by a different route: a unit is issued by a trust, not a company, so it is not a share at all and drops into the residence-only residual clause.

Two things stay taxable in India, and they are the ones to check before you assume the answer. A stake of 10% or more in a single Indian company. And shares or units whose value comes mainly from Indian immovable property, which the treaty sends back to India however small your holding.

Where the units-are-not-shares argument fits from Spain

The units-are-not-shares point turns on the wording of the residual clause, and this treaty's wording helps you. In 2025 the Mumbai Tribunal used the point in Anushka Sanjay Shah: a fund unit is not a company share, so a unit gain falls in the residual clause. Because this treaty's residual clause is residence-only, that clause taxes the gain only in the country of residence.

You do not have to lean on it here, because your listed shares are already outside India's reach at a stake under 10%. It earns its keep the day you cross that line on a company: the shares become taxable in India, and the fund units still do not.

What India can and cannot tax here

On a normal private portfolio, nothing. What decides it is your stake, not the asset type.

What you soldIndian tax on the gain
Listed company shares, stake under 10%Nil in India, taxable only in Spain
Listed company shares, stake 10% or more12.5% over Rs 1.25 lakh long term, 20% short term (Sections 112A and 111A)
Equity or debt mutual fund unitsNil in India, taxable only in Spain
Shares or units mainly backed by Indian propertyTaxable in India whatever your stake

The 10% is measured on your holding in that one company, so a diversified portfolio never gets near it. The property-rich row is the one that catches people out: a real-estate fund or an InvIT can be taxable in India even though an equity fund is not, so check what each fund actually holds before you treat the whole folio the same way.

Spain taxes the whole portfolio instead

Spain taxes the whole gain instead, in the savings base, at rates that start at 19 per cent and rise to 30 per cent on the largest gains. You also report the Indian holdings themselves on the Modelo 720 once they pass the reporting threshold, which is a separate obligation from the tax and carries its own penalties.

This treaty carries two anti-abuse gates, the Limitation of Benefits article added by the 2012 Protocol and the multilateral instrument's Principal Purpose Test, so the Spanish residence has to be real and not arranged for the exemption. And the multilateral instrument rewrote the property-rich clause with a 365-day look-back that reaches comparable interests, so a fund mainly backed by Indian property stays taxable in India even though an equity fund does not.

So the treaty does not make the gain tax-free, it moves it. There is no Indian tax left to credit, which makes the Spanish computation the one that decides what you actually pay.

The India paperwork: TDS, TRC and Form 10F

Give the fund house your Spanish Tax Residency Certificate and Form 10F, now Form 41, before you redeem, claiming the Article 14 exemption. Without them it deducts TDS under Section 195, which becomes Section 393(2) from FY 2026-27, because it has no way of knowing your stake or your residence.

Before a large redemption, go one better and get a nil or lower deduction certificate, Form 13 under Section 197, now Form 128 under Section 395. That stops the withholding at source rather than leaving you to chase it.

If tax comes out anyway, you reclaim it on an Indian return, ITR-2, with the treaty position and the evidence behind it: your stake in each company and what each fund actually holds.

A worked example: Anita's Madrid sale

Anita, an NRI in Madrid, redeems Indian equity mutual funds for a gain of Rs 8 lakh and sells listed Indian shares held nine months for a short-term gain of Rs 2 lakh. The shares are a small holding in a large listed company, well under 10%.

India taxes neither. The Rs 8 lakh unit gain sits in the residence-only residual clause, and the Rs 2 lakh share gain sits below the 10% line, so Article 14 leaves both taxable only in Spain. Without the paperwork the fund house would still withhold on the Rs 8 lakh, so Anita lodges the Spanish TRC and Form 10F first, and the whole Rs 10 lakh is reported and taxed in Spain alone.

Change one fact and the answer changes. Had Anita held 10% or more of that company, or had it been a company whose value sits mainly in Indian property, India would tax that share gain and Spain would relieve it under Article 25.

What's involved

What the CA actually does

  1. 1

    Check every holding against the stake line

    We go through each holding and confirm it sits under the 10% line and is not property-backed, which is what the exemption turns on, then compute Indian tax only on anything that does not.

  2. 2

    Set the treaty position honestly

    We put the Article 14 claim on record with the evidence behind it, your stake per company and what each fund actually holds, so the exemption stands up rather than being asserted.

  3. 3

    Cut or recover the TDS

    We reconcile the fund house's TDS against your 26AS and reclaim any excess through your return, or get a lower-deduction certificate, Form 13 under Section 197 and now Form 128 under Section 395, before a large redemption so less is withheld.

  4. 4

    Hand your Spanish adviser clean figures

    We give you the Indian gain, tax paid and dates in the form your Spanish adviser needs, so the Article 25 credit lines up and nothing is taxed twice.

What to have ready

Documents you'll typically need

  • Purchase and redemption statements for your mutual fund units
  • Contract notes for any listed shares you sold
  • Whether each holding is equity, debt or a direct share, and the holding period
  • The TDS deducted, from your 26AS
  • PAN, passport and your Spanish tax residency certificate

References on this page

  • India-Spain DTAA Article 14: India may tax a share gain only on a stake of 10% or more, or a property-rich company; the residual clause makes everything else, mutual fund units included, taxable only in the country of residence
  • Mutual fund units are not company shares: Anushka Sanjay Shah v. ITO, Mumbai ITAT, 26 March 2025 (decided on the residence-only India-Singapore residual clause)
  • Section 112A: LTCG on listed shares and equity mutual funds at 12.5%, no indexation, over Rs 1.25 lakh, for sales on or after 23 July 2024
  • Section 111A: STCG on listed shares and equity mutual funds at 20%, for sales on or after 23 July 2024
  • Section 50AA: specified debt mutual fund units (over 65% in debt) bought on or after 1 April 2023 taxed at slab rate as short-term, the Indian rate that applies to any unit the treaty exemption does not cover
  • India-Spain DTAA Article 25: relief from double taxation, by credit for the tax paid in the other country
  • Section 195 (Section 393(2) from FY 2026-27): TDS on a redemption to a non-resident, corrected with a TRC and Form 10F (Form 41 from FY 2026-27)
  • Section 197 (Section 395 from FY 2026-27): lower or nil TDS certificate, Form 13 (Form 128), before a large redemption

Frequently asked questions

Common questions

No, and neither are your listed shares on a normal holding. The units are taxable only in Spain under the residence-only residual clause, and Article 14 only lets India tax a share gain where your stake reaches 10%, which a private portfolio does not. India keeps the right on a stake of 10% or more and on anything mainly backed by Indian property.

You are in a better position than a Singapore resident, not a worse one. A Singapore resident's escape covers fund units and leaves direct Indian company shares taxable in India. Yours covers both, because Article 14 only gives India a share gain at a stake of 10% or more. The catch is the same for both of you: it is a claim, not an automatic exemption, so without a TRC on file tax still gets withheld.

Yes, the Rs 1.25 lakh long-term equity exemption under Section 112A applies to NRIs. What you do not get is the resident's option to set capital gains against the basic exemption limit, so the 12.5% and 20% rates apply from the first rupee of gain above that Rs 1.25 lakh equity slice.

Usually yes, and it is how you get your money back. If any TDS came out of the redemption, the return is the only route to a refund, and the correct Indian tax being nil means the refund is the whole amount. Filing also puts the Article 14 claim on record with the stake and fund details behind it, which is what you would want on file if the position is ever questioned.

Sold Indian shares or funds while living in Spain?

Send us your redemption and share statements and your TRC. A practising CA will compute the Indian tax, set the treaty position right and recover any over-deducted TDS. Free call, no obligation.

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