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Treaty withIndia

The UAE and India tax treaty.

What the treaty means if you or your company has income, profits or residence in both countries.

Position as at 12 November 2026

Applies from: UAE side: income from 1 January 1994. India side: Indian tax years starting 1 April 1994. Current 10% dividend rate: from 1 January 2008 (UAE) / 1 April 2008 (India), after the 2007 Protocol came into force on 3 October 2007.

Entry into force: Sources differ. In force since 22 September 1993 according to India's official notification and the UAE's MLI filing. The UAE Ministry of Finance 2023 table gives 15 September 1993.

Signed: 29 April 1992

Withholding rates

What tax is taken at source.

Last checked 12 November 2026. Sources

What tax is taken at source.
PaymentTreaty capDomestic rate without treatyConditions and evidence
DividendsArt. 10 10% Indian rate without the treaty: 20% (10% for dividends from an IFSC unit), plus surcharge and cess

India can tax dividends paid to a UAE resident at no more than 10%. No minimum shareholding needed. Dividends to the UAE Government and named bodies (the UAE Central Bank, the Abu Dhabi Investment Authority and the Abu Dhabi Fund for Economic Development) are exempt.

  • India's 10% cap on dividends applies only if the UAE recipient is the beneficial owner of the dividends (Art 10(2), as replaced by the 2007 Protocol).
4 of 4 official sources

Art. 10
InterestArt. 11 5% / 12.5% Indian rate without the treaty: 20% on foreign-currency loans and bonds; other interest at the rates in the Income-tax Act 2025 (s 207 and s 393), plus surcharge and cess

India can tax interest at no more than 5% on loans from a bank or similar financial institution, and 12.5% on other interest. Interest to the UAE Government, its local governments or its central bank is exempt.

  • India's 5% and 12.5% caps on interest apply only if the UAE recipient is the beneficial owner of the interest (Art 11(2)).
3 of 3 official sources

Art. 11
RoyaltiesArt. 12 10% Indian rate without the treaty: 20%, plus surcharge and cess

India can tax royalties at no more than 10% of the gross amount. This includes payments for renting industrial, commercial or scientific equipment.

  • India's 10% cap on royalties applies only if the UAE recipient is the beneficial owner of the royalties (Art 12(2)).
  • The treaty has no technical-fees article. A fee gets the 10% royalty cap only if it pays for an Art 12(3) item, such as know-how.
3 of 3 official sources

Art. 12

The treaty can reduce the rate to the lower of the two, usually only once you claim it with a UAE tax residence certificate. The UAE charges 0% on these payments. Position as at 12 November 2026.

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Sources for the India treaty

Sources differ

Applies from: UAE side: income from 1 January 1994. India side: Indian tax years starting 1 April 1994. Current 10% dividend rate: from 1 January 2008 (UAE) / 1 April 2008 (India), after the 2007 Protocol came into force on 3 October 2007.

Entry into force: In force since 22 September 1993 according to India's official notification and the UAE's MLI filing. The UAE Ministry of Finance 2023 table gives 15 September 1993.

Agreement between the Government of the Republic of India and the Government of the United Arab Emirates for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital

Income Tax Department, India

Last checked 12 November 2026

Income Tax Department, India
Income Tax Department, India

Last checked 12 November 2026

Income Tax Department, India
OECD MLI filing

Last checked 12 November 2026

OECD MLI filing
UAE Ministry of Finance, treaty table (2023)

Last checked 12 November 2026

UAE Ministry of Finance, treaty table (2023)

What changed on this page

  1. Recorded

    Entry into force: 22 September 1993 according to India's official notification and the UAE's MLI filing. The UAE Ministry of Finance 2023 table gives 15 September 1993.

Position as at 12 November 2026. How we check

Moving from India

Where you are resident for tax.

UAE individual: present in the UAE "for a period or periods totalling in the aggregate at least 183 days in the calendar year concerned"; UAE company: "incorporated in the UAE and which is managed and controlled wholly in UAE" (Art 4(1)(b)).

Running a company

When a India business is taxed in the UAE.

Place of effective management (Art 4(4)); not changed by the MLI (UAE reserved Art 4).

Selling assets

Selling shares or property.

May be taxed where the property is (Art 13(1)). Shares of a company whose property "consists directly or indirectly principally of immovable property" may be taxed in the situs state (Art 13(3)); other shares in a resident company may be taxed in that state (Art 13(4)).

Pensions

Pensions and retirement income.

Private pensions and annuities: residence state only (Art 19(1)). Government-service pensions: taxable only in the paying state, unless the individual is a resident and national of the other state (Art 18(2)(a)-(b)).

Treaty updates

How the multilateral instrument changes this treaty.

Both countries list this treaty under the OECD Multilateral Instrument. A principal purpose test (benefits can be denied if getting them was one of the main purposes of an arrangement) replaced the treaty's old anti-abuse Article 29.

Checked by PBF against official sources. Position as at 12 November 2026. How we check

PBF UAE Tax Hub. General information, not advice.

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