DTAA Calculator India 2026 — Double Taxation Relief
Calculate DTAA (Double Taxation Avoidance Agreement) relief on income taxed in India and abroad. Compare treaty rates across 12 countries for interest, dividends, royalties, capital gains, and salary. Compute Foreign Tax Credit under Section 90 (DTAA countries) or Section 91 (non-DTAA countries). Includes complete documentation checklist: Tax Residency Certificate (TRC), Form 10F, Form 67 timeline. Based on India's bilateral tax treaties as notified by CBDT, Income Tax Act Sections 90/91, and Rule 128 for FY 2025-26.
How to Use This Calculator
DTAA Relief tab
Select your country of residence, the type of income (interest, dividend, royalty, capital gains, or salary), enter the income amount in ₹, the foreign tax already paid, and your Indian tax bracket. The calculator computes your Indian tax liability, the applicable DTAA treaty rate, the Foreign Tax Credit (lower of foreign tax paid or Indian tax), and your net Indian tax payable after DTAA relief. This shows you exactly how much you save by claiming DTAA benefits.
Country Comparison tab
Compare how the same income would be taxed under DTAAs with US, UK, UAE, Singapore, Canada, Australia, and Germany. See the DTAA rate, tax under treaty, and savings for each country side by side. This is useful for NRIs considering which country to establish tax residency in, or for CAs advising clients across multiple jurisdictions.
How to Claim tab
A complete documentation checklist with step-by-step instructions for claiming DTAA relief. Covers Tax Residency Certificate (TRC) from each country, Form 10F filing on incometax.gov.in, Form 67 (mandatory before ITR), and supporting documents. Includes the FY 2025-26 timeline with critical deadlines.
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The Formula
DTAA relief in India uses the credit method (most common). The foreign tax credit is computed as follows:
Indian Tax on Foreign Income = Income × Indian Tax Rate (slab + cess)
DTAA Rate = Treaty-specified maximum rate for that income type
Applicable Tax = Lower of (Indian Tax Rate, DTAA Rate) × Income
Foreign Tax Credit = Lower of:
(a) Actual foreign tax paid on that income, OR
(b) Indian tax attributable to that income
Net Indian Tax Payable = Indian Tax − Foreign Tax Credit
(Cannot be negative — minimum is ₹0)
Total Tax Burden = Net Indian Tax + Foreign Tax Already Paid
Example (₹10,00,000 interest, US resident, 30% bracket):
Indian domestic tax = 10,00,000 × 31.2% = ₹3,12,000
DTAA rate (India-US, interest) = 15%
Tax under DTAA = 10,00,000 × 15% = ₹1,50,000
Foreign tax paid (US) = ₹1,50,000
FTC = min(₹1,50,000, ₹1,50,000) = ₹1,50,000
Net Indian tax = ₹1,50,000 − ₹1,50,000 = ₹0
Total burden = ₹0 + ₹1,50,000 = ₹1,50,000 (15% effective)
Without DTAA: ₹3,12,000 + ₹1,50,000 = ₹4,62,000 (46.2%)
DTAA saves ₹3,12,000
Note: Surcharge applicability depends on total Indian income. For income above ₹50 lakh, surcharge of 10-25% applies on the tax amount. The calculator uses simplified effective rates. Consult a CA for precise computation with surcharge tiers.
Example
Priya — Software engineer in California, earns dividends from Indian stocks
Priya (31) is a US tax resident working in San Francisco. She holds Indian mutual funds and stocks that paid ₹5,00,000 in dividends during FY 2025-26. The US also taxes her worldwide income. She needs to ensure she is not taxed twice on the same dividends.
Step 1: Identify the DTAA Rate
Step 2: Compute Indian Tax and FTC
Step 3: Documents Filed
Priya's outcome: Instead of paying ₹1,56,000 in Indian tax PLUS US tax (total ₹2,31,000+), she pays only the 15% DTAA rate in India, which is fully credited against her US tax liability. Her effective total tax on the ₹5L dividend is just 15% (₹75,000) instead of 46%+ without DTAA.
DTAA Rates — India Treaties (FY 2025-26)
DTAA Rates by Country — Interest, Dividend, Royalty
| Country | Interest | Dividend | Royalty/FTS | Treaty Year |
|---|---|---|---|---|
| United States | 15% | 15% / 25% | 10% / 15% | 1989 |
| United Kingdom | 15% | 10% / 15% | 10% / 15% | 1993 |
| UAE | 12.5% | 10% | 10% | 1992 |
| Singapore | 15% | 10% / 15% | 10% | 1994 |
| Canada | 15% | 15% / 25% | 10% / 15% | 1996 |
| Australia | 15% | 15% | 10% / 15% | 1991 |
| Germany | 10% | 10% | 10% | 1995 |
| Japan | 10% | 10% | 10% | 1989/2006 |
| Netherlands | 10% | 10% | 10% | 1988 |
| France | 10% | 10% | 10% | 1992 |
| South Korea | 10% | 15% | 10% | 1985/2015 |
| Malaysia | 10% | 5% | 10% | 2012 |
Rates shown are the general treaty rates for individual taxpayers. Some DTAAs have different rates based on shareholding percentage (dividends) or type of royalty. Where two rates are shown (e.g., 15%/25%), the lower rate applies to portfolio holdings and the higher to substantial holdings (typically >10% or >25%). Source: incometax.gov.in DTAA texts as of March 2026.
Indian Domestic Tax Rates on Non-Resident Income (Without DTAA)
| Income Type | Domestic Rate | Section | Notes |
|---|---|---|---|
| Interest | Slab rate (5-30%) + cess | Section 195 | NRO FD interest: 30% TDS + cess (~31.2%) |
| Dividend | Slab rate + cess | Section 195/196D | Post-2020: taxable in recipient's hands. 20% TDS for non-residents. |
| Royalty/FTS | 10% + cess | Section 115A | Special rate for non-residents under Section 115A |
| LTCG (shares/MF) | 12.5% + cess | Section 112A | Post July 2024: 12.5% on LTCG exceeding ₹1.25L |
| STCG (equity) | 20% + cess | Section 111A | Post July 2024: 20% on equity STCG |
Rates are as per Finance Act 2025 and Union Budget 2024 amendments. Surcharge applies based on total Indian income. 4% Health & Education Cess applies on tax + surcharge.
Key Concepts
Section 90 vs Section 91 — DTAA vs Unilateral Relief
Section 90 applies when India has a DTAA with the other country. It provides two types of relief:
- Exemption method: Income is taxed in only one country. Rare in Indian DTAAs.
- Credit method: Income is taxed in both countries, but tax paid in one country is credited against tax in the other. This is the standard method in most Indian DTAAs.
Section 91 applies when there is NO DTAA with the other country. India grants unilateral relief:
- Credit = Indian tax rate on that income, or the foreign tax rate, whichever is lower
- The income must have been taxed in both countries
- The taxpayer must be a resident of India for that year
Key difference: Section 90 gives you the benefit of treaty rates (which may be lower than domestic rates). Section 91 uses domestic rates as the ceiling.
Form 67 — Foreign Tax Credit claim (critical deadline)
Form 67 is mandatory for claiming Foreign Tax Credit (FTC) in India.
- What it contains: Country-wise details of foreign income, tax paid, DTAA article claimed, and computation of FTC
- Where to file: incometax.gov.in → e-File → Income Tax Forms → Form 67
- Deadline: Must be filed ON OR BEFORE the due date of filing ITR (31 July for non-audit, 31 Oct for audit)
- Consequence of late filing: FTC claim may be rejected. Some ITAT tribunals have allowed late filing, but it is risky. Always file before ITR.
- Attachments: Proof of foreign tax paid — copy of foreign tax return, withholding certificate, Form 16A equivalent from foreign employer/bank
- Rule 128(9): The governing rule that mandates Form 67 filing for FTC
Tax Residency Certificate (TRC) — how to obtain
A Tax Residency Certificate (TRC) is issued by the tax authority of your country of residence, proving you are a tax resident there. It is the primary document for claiming DTAA benefit.
- US: IRS Form 6166 — apply by mailing Form 8802 to IRS. Processing takes 4–6 weeks. Fee: $85.
- UK: HMRC issues TRC upon request via Government Gateway. 2–4 weeks.
- UAE: Federal Tax Authority (FTA) via EmaraTax portal. Must have UAE tax registration. 1–2 weeks.
- Singapore: IRAS via mytax.iras.gov.sg. 2–3 weeks.
- Canada: CRA — request via My Account or by mail. 4–6 weeks.
- Australia: ATO via myGov portal. 2–4 weeks.
- Germany: Finanzamt (local tax office) — request Ansässigkeitsbescheinigung. 2–4 weeks.
Validity: TRC is typically valid for one Financial Year. Renew annually.
Form 10F — electronic filing requirement
Form 10F is a self-declaration filed by the non-resident taxpayer, required alongside the TRC for DTAA benefit.
- Mandatory electronic filing: Since April 2022 (CBDT notification), Form 10F must be filed electronically on incometax.gov.in
- Who must file: Any non-resident claiming DTAA benefit for income from India
- Fields: Name, PAN/TIN, status (individual/company), nationality, country and address of residence, Tax Identification Number in residence country, period of tax residency
- PAN requirement: Non-residents without Indian PAN can still file Form 10F, but having PAN is recommended for faster processing
- Submit to payer: After filing Form 10F, provide the acknowledgment + TRC to the Indian payer (bank, company) to get lower TDS at source
Limitation of Benefits (LOB) — anti-treaty-shopping clause
Many Indian DTAAs include a Limitation of Benefits (LOB) clause to prevent treaty shopping — routing income through a country solely to get favourable DTAA rates.
- India-Singapore DTAA: Post-2005 amendment includes LOB for capital gains. Shell companies incorporated in Singapore solely for investing in India may not get DTAA benefits.
- India-Mauritius DTAA: Post-2017 amendment removed capital gains exemption. Now fully taxable in India.
- India-Cyprus DTAA: Renegotiated in 2016, removed capital gains exemption.
- General test: The taxpayer must demonstrate that the arrangement has "substantial economic purpose" beyond tax avoidance.
- GAAR: India's General Anti-Avoidance Rule (effective from 2017) can override DTAA benefits if the arrangement is deemed "impermissible avoidance".