{"version":2,"checked_at":"2026-11-12","rows":[{"payment":"dividends","home_rate":"0% (UAE Corporate Tax Law Art 45(1): State Sourced Income of a Non-Resident not attributable to a PE or nexus is taxed at 0% withholding tax)","partner_rate":"Income-tax Act 2025 s 207: dividends 20% (10% for dividends from an IFSC unit); interest on foreign-currency loans and bonds 20%; certain infrastructure debt fund interest 5%; other specified interest at the rates in s 393(2); royalties and fees for technical services 20%. Surcharge and cess apply under the Finance Act; not modelled here.","treaty_rate":"10% (Art 10(2)); no participation threshold. Government and specified bodies exempt (Art 24).","conditions":"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).\nGovernment exemption: Art 24(1)-(2)\nMLI principal purpose test applies (see mli)","position_as_at":"2026-11-12","source":"https://www.incometaxindia.gov.in/w/uae-comprehensive-agreements-1"},{"payment":"interest","home_rate":"0% (UAE Corporate Tax Law Art 45(1): State Sourced Income of a Non-Resident not attributable to a PE or nexus is taxed at 0% withholding tax)","partner_rate":"Income-tax Act 2025 s 207: dividends 20% (10% for dividends from an IFSC unit); interest on foreign-currency loans and bonds 20%; certain infrastructure debt fund interest 5%; other specified interest at the rates in s 393(2); royalties and fees for technical services 20%. Surcharge and cess apply under the Finance Act; not modelled here.","treaty_rate":"5% on loans from banks or similar financial institutions; 12.5% otherwise (Art 11(2)); government and central bank exempt (Art 11(3)).","conditions":"5% only if the loan is granted by a bank carrying on bona fide banking business or a similar financial institution\nIndia's 5% and 12.5% caps on interest apply only if the UAE recipient is the beneficial owner of the interest (Art 11(2)).","position_as_at":"2026-11-12","source":"https://www.incometaxindia.gov.in/w/uae-comprehensive-agreements-1"},{"payment":"royalties","home_rate":"0% (UAE Corporate Tax Law Art 45(1): State Sourced Income of a Non-Resident not attributable to a PE or nexus is taxed at 0% withholding tax)","partner_rate":"Income-tax Act 2025 s 207: dividends 20% (10% for dividends from an IFSC unit); interest on foreign-currency loans and bonds 20%; certain infrastructure debt fund interest 5%; other specified interest at the rates in s 393(2); royalties and fees for technical services 20%. Surcharge and cess apply under the Finance Act; not modelled here.","treaty_rate":"10% (Art 12(2)); definition includes industrial, commercial or scientific equipment.","conditions":"India's 10% cap on royalties applies only if the UAE recipient is the beneficial owner of the royalties (Art 12(2)).\nThe 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.","position_as_at":"2026-11-12","source":"https://www.incometaxindia.gov.in/w/uae-comprehensive-agreements-1"}]}