Chapter DT9552
| Published date | 20 May 2016 |
| Record Number | DT9552 |
| Court | HM Revenue & Customs |
| Issuer | HM Revenue & Customs |
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which India is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
| Portfolio dividends | 10% | 11 |
| Dividends on direct investments | 10% | 11 |
| Conditions for lower rate on dividends on direct investments | N/A | N/A |
| Property income dividends | 15% | 11 |
| Interest | 15% (Notes 1 and 2) | 12 |
| Royalties | 15% (Note 3) | 13 |
| Fees for technical services | 15% (Note 4) | 13 |
| Government pensions | Government pensions taxable only in India for services rendered to India | 19 |
| Other pensions | Taxable only in the UK | 20 |
| Arbitration | No | N/A |
Note 1: Interest arising in India and beneficially owned by a UK resident bank carrying on a bona fide banking business is taxable in India at a reduced rate of 10%.
Note 2: The following interest is exempt from tax in India:
- interest paid...
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