UK–India double tax treaty: what UK companies investing in India actually pay (2026 guide)

Short answer: Under the UK–India double tax treaty, India withholds 10% on dividends paid to a UK company, 15% on royalties, fees for technical services and interest (10% for equipment royalties and UK bank loans), against 20.8%–21.84% without it [1][12]. Service fees that do not "make available" know-how are not taxed in India without a permanent establishment, but India keeps the right to tax your gain on selling the Indian subsidiary [1][14]. Because the UK exempts dividends and most share-sale gains, that Indian tax is a final cost, so the real decisions are how you hold, charge, fund and staff the Indian business.

Who this is for: CFOs, heads of tax and general counsel of UK groups setting up, funding or exiting an Indian subsidiary or GCC, and their advisers.

UK–India DTAA withholding tax rates at a glance (tax year 2026-27)

*Domestic 20% plus 2% or 5% surcharge and 4% cess; treaty rates carry neither [10][12][20]. Interest on UK Export Finance-backed loans is exempt (Art 12(4)) [1].

What the UK–India double taxation agreement covers in 2026

The India UK DTAA is the 1993 Convention, amended by a 2013 Protocol and modified from 1 April 2020 by the OECD Multilateral Instrument (MLI) [1][2][27]. From 1 April 2026 India applies it through section 159 of the Income-tax Act 2025 (formerly section 90) where more beneficial, subject to India's general anti-avoidance rule (GAAR) [9]. Earlier payments follow the 1961 Act.

Fees for technical services: substance, not labels

Services are FTS under Article 13(4) if ancillary to a royalty or equipment rental or, otherwise, only if they "make available technical knowledge, experience, skill, know-how or processes" [1]. In Tungsten Automation England (2025) the Delhi High Court held that the Indian recipient must be able to apply the technology on its own [14]. Routine management, IT and finance support is usually business profit.

The test follows what is delivered, not the invoice label: in Ernst & Young U.S. LLP (Delhi High Court, June 2026, US treaty) secondee "reimbursements" were FTS because know-how passed [22]. Records must describe accurately whether know-how is transferred; where it is, accept 15%.

Royalties, and what is not a royalty

In Financial and Risk Organisation Ltd (Delhi High Court, 10 February 2026) a UK company's distribution fees for data products were held not to be royalties; the court set aside a 15% withholding certificate and ordered nil certificates within 15 days for 2026-27 and 30 days for later years [13]. Certificates are now sought on Form 128 (section 395) [20].

Parent loans: the FEMA gate before the 15%

A UK parent loan is an external commercial borrowing (ECB) under the RBI's Borrowing and Lending Regulations as amended from 16 February 2026: three-year minimum average maturity, pricing in line with market conditions and at arm's length for a related-party lender, a ceiling of the higher of USD 1 billion of outstanding ECB or total borrowing of 300% of net worth, a loan registration number before drawdown and a Form ECB 2 return within seven calendar days of the end of any month in which funds are received or the loan is serviced [23][34]. India also caps deductions for interest to a non-resident associated enterprise at 30% of EBITDA (s.177 Income-tax Act 2025) [33].

Capital gains: India taxes your exit

Article 14 leaves gains to domestic law [1]. India taxes a long-term gain on unlisted shares at 12.5% plus surcharge and cess (13.0%–13.65%) and a gain within 24 months at 36.4%–38.22% [20][24]. From 1 April 2026 buy-backs are capital gains again (s.69(1)), but a UK parent holding more than 10%, directly or indirectly, is a "promoter" and pays an additional 17.5% on a long-term gain (s.69(2)), taking the rate to 30% before surcharge and cess, roughly a third all-in once the Finance Act 2026's 12% surcharge on the additional tax is added [25][35][36]. See India withholding tax rates 2026 and how to repatriate profits. Selling a foreign holdco that derives at least 50% of its value from India is taxed under the indirect-transfer rule [26].

When a UK company can lose treaty benefits

• Principal purpose test (PPT): applies since 1 April 2020; CBDT Circular 1/2025 applies it prospectively [1][28].
• Recorded disagreement: India says the PPT replaces only Article 28C, so it also runs the "main purpose" tests in Articles 11(6), 12(11) and 13(9); the UK disagrees [1].
• Beneficial ownership: back-to-back licences or loans can lose the treaty rate.
• GAAR: overrides the treaty; after Tiger Global (Supreme Court, January 2026) a TRC is not conclusive [29].
• UK LLPs: treaty residence extends only to income taxed in the UK in the partnership's or partners' hands (Art 4(1)(b)) [1].
• Dual residence and disputes: a UK holdco run from India risks Indian residence; mutual agreement claims must be made within three years [1].

PE risk for UK staff under the treaty: the 90-day and 30-day limbs

India taxes UK business profits only through a PE, at 36.4%–38.22% [1][20]: a fixed place or six-month project; a service PE where personnel furnish services in India for more than 90 days in any 12 months, or 30 days for an associated enterprise such as your subsidiary (Art 5(2)(k)); or a dependent agent concluding contracts (the MLI's wider agency test was not adopted) [1]. For what a PE costs, see India corporate tax rate for foreign companies: subsidiary vs branch vs PE.

Only physical presence counts: the Delhi High Court rejected a "virtual" service PE under the Singapore treaty (Clifford Chance, 2025) and, on press reports, the UK treaty (EY (EMEIA) Services, 2026) [15][16]. Secondments split: Goldman Sachs International (Mumbai Tribunal, 2026) treated reimbursements for secondees controlled by the Indian entity as salary [17]; EY U.S. found FTS where secondees kept their foreign lien [22]. See Permanent establishment in India (employees, EOR, agents).

How to claim UK–India tax treaty relief in India (2026 procedure)

1. Apply to HMRC online for a certificate of residence (TRC) once the Indian tax year has begun, naming the India convention, income type and period; HMRC will not certify future periods [3].
2. File Form 41 (formerly Form 10F) under s.159(8), uploading the TRC, once per tax year; no PAN needed [7]. See Form 10F (now Form 41) and tax residency certificate.
3. Give each payer your Rule 217 details so the 20% no-PAN rate does not apply [8].
4. The payer files Form 145 (ex-15CA), plus Form 146 (ex-15CB) above INR 5 lakh [11].
5. Apply for a Form 128 certificate before paying non-FTS fees [13].
6. File an Indian return for a PE or capital gain, and where tax was withheld below the domestic s.207 rate, because the s.207(8) exemption applies only where tax was deducted at not less than that rate [37].

UK side: what relief you get at home

• Dividends are exempt (CTA 2009 Part 9A); electing to tax them rarely helps when Indian tax totals about 32.65% [4].
• Royalties, FTS and interest are taxed at 25%, with credit capped at UK tax on net income [5][6]: thin-margin fees and Patent Box income lose much of a 15% credit; gross-up clauses shift it to the subsidiary.
• Exit gains are usually SSE-exempt, so Indian tax is not creditable [30].
• CFC: an Indian subsidiary normally qualifies for an exemption; check the 15% manufacturing regime [30].

For the full UK-side analysis (the dividend exemption, CFC rules and credit for Indian withholding), see UK tax on an Indian subsidiary: dividend exemption, CFC and relief for Indian tax.

UK–India CETA, the investment treaty gap and the DTAA

The UK–India trade deal (CETA), in force since 15 July 2026, does not apply to direct taxes and gives the tax convention priority on any inconsistency (Art 28.4) [31]. It has no investment chapter, and the terminated 1994 India–UK bilateral investment treaty protects only investments made before termination, for 15 years (Article 15), so to March 2032 [32][38][42]. The Double Contributions Convention keeps staff posted to India after 15 July 2026 in UK National Insurance for up to 60 months [18][19]. See India–UK trade deal (CETA) in force: what UK businesses can use now (ATB Legal).

Decision table: hold India directly from the UK, or through a holding company?

*Top surcharge band [1][21][26].

For most UK operating groups direct holding is the default; a holdco pays only through exit or fee treatment backed by real substance [29]. See Invest in India: choosing a holding company jurisdiction (hub).

Worked example: UK parent with an Indian subsidiary

Illustrative only. Tax year 2026-27; FX: INR 127 = GBP 1, INR 96 = USD 1, INR 107 = EUR 1 (FBIL reference rates, 12 October 2026, rounded) [41]; 5% surcharge band; no UK costs attributed to the royalty. Albion Engineering Ltd (UK) owns Albion India Pvt Ltd. Figures in INR crore.

Indian tax on distributed profit: 25.168% + (10% × 74.832%) = 32.65%. The treaty saves 6.552 − 3.000 = INR 3.552 crore (about GBP 280,000) on the dividend. A mis-scoped service bears INR 0.6 crore of tax on INR 0.8 crore of profit (75%). One engineer spending 45 days at the subsidiary crosses the 30-day limb.

Risks and common mistakes, ranked

1. Mis-scoped services: 15% (or 21.84%) on services transferring no know-how, or nil claimed where know-how passes.
2. Secondments without a PE plan.
3. No TRC, Form 41 or Rule 217 details: up to 21.84% withholding, and 20% instead of 12.5% on an exit [7][8].
4. Budgeting UK credit for dividend or exit tax.
5. Holdcos without substance [29].
6. Parent loans outside ECB rules.
7. 1961-Act forms for 2026-27 payments; overlooking the IGST (18% for most services) the subsidiary must pay under reverse charge on imported services, creditable only if it makes taxable supplies [39].

Checklist for the CFO or group tax head

• Map each payment to its treaty article and UK credit.
• Scope and document services so agreement, deliverables and evidence consistently show whether know-how is made available.
• Obtain the HMRC certificate; file Form 41; send Rule 217 details.
• Apply for Form 128 certificates before the first invoice.
• Structure parent loans as ECBs.
• Log UK staff days in India; obtain DCC certificates.
• Price the exit at 13.65%, unrelieved in the UK.

How ATB Corporate can help

ATB Corporate advises companies and investors on entering, structuring and operating in India and the UAE: choosing the entry route and holding structure, tax and exchange-control planning, regulatory compliance, and setting up and running the local business. To discuss your plans, contact ATB Corporate.

FAQ

Is there withholding tax on dividends paid from India to a UK parent company?

Yes, India withholds tax on dividends paid to a UK parent company at 10% under the UK–India double tax treaty, against 20.8%–21.84% without treaty benefits. The UK exempts the dividend from corporation tax, so no UK credit arises and the Indian 10% is a final cost. To secure the treaty rate, the UK parent needs an HMRC certificate of residence, Form 41 and Rule 217 details [1][4][7][8].

Does the India UK DTAA cover fees for technical services?

Yes, the India–UK DTAA covers fees for technical services at 15% under Article 13, but only where the service makes available technical knowledge, experience, skill, know-how or processes, or is ancillary to a royalty or equipment rental. Routine management, IT and finance support that transfers no know-how is usually business profit, taxable in India only through a permanent establishment. The test follows what is delivered, not the invoice label [1][14][22].

How many days can UK staff work in India before creating a permanent establishment?

UK staff can furnish services in India for up to 90 days in any 12 months before creating a service permanent establishment for their UK employer, but the limit falls to 30 days where they serve an associated enterprise such as the Indian subsidiary (Article 5(2)(k)). Only physical presence counts. For secondees, the risk is high after 30 days unless the subsidiary controls and pays them; one engineer spending 45 days at the subsidiary crosses the 30-day limb [1][17].

What documents does a UK company need to claim treaty benefits in India in 2026?

To claim UK–India treaty benefits in India in 2026, a UK company needs an HMRC certificate of residence, Form 41 (which replaced Form 10F) filed once per tax year with that certificate uploaded, and Rule 217 details given to each Indian payer so the 20% no-PAN rate does not apply. The Indian payer files Form 145, plus Form 146 above INR 5 lakh, and a Form 128 certificate should be sought before paying non-FTS fees [3][7][8][11][13].

Does a UK LLP get India–UK tax treaty benefits?

A UK LLP gets India–UK tax treaty benefits only for income that is taxed in the UK, whether in the LLP's own hands or in its partners' hands, under Article 4(1)(b) of the treaty. Income not taxed in the UK in either set of hands falls outside the treaty's residence rule, so treaty rates cannot be claimed on it. Qualifying income remains subject to the principal purpose test, beneficial-ownership rules and India's GAAR [1][28][29].

Does the treaty protect a UK company from Indian capital gains tax?

No, the UK–India treaty does not protect a UK company from Indian capital gains tax, because Article 14 leaves gains to Indian domestic law. India taxes a long-term gain on unlisted shares at 12.5% plus surcharge and cess (13.0%–13.65%) and a gain within 24 months at 36.4%–38.22%. The UK substantial shareholding exemption usually exempts the gain at home, so the Indian tax is not creditable and is a final cost [1][20][24][30].

Does the UK–India CETA change the double taxation agreement?

No, the UK–India CETA does not change the double taxation agreement, because the trade deal does not apply to direct taxes and gives the tax convention priority on any inconsistency (Article 28.4). The CETA, in force since 15 July 2026, also has no investment chapter. A separate Double Contributions Convention keeps staff posted to India after 15 July 2026 in UK National Insurance for up to 60 months [18][31][32].

Related reading

• India market entry for UK businesses and investors
• US–India tax treaty: guide for US companies
• The indirect-transfer cases: Vodafone, Cairn and the treaty backstop
• India tax advisory
• India structuring
• FEMA advisory
• India GCC tax structuring
• India bilateral investment treaty protection (ATB Legal)

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Disclaimer: This article is general information, not legal or tax advice. Treaty positions depend on facts, and Indian and UK law change frequently; verify against current law and take advice before acting.