Treaty detail
Canada - India tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1996-01-11
Effective
1997-05-06
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 25% · Corporate rate: 15%
The lower 15 percent corporate rate generally depends on direct-ownership thresholds. India's domestic dividend regime, modified in 2020 to shift taxation to shareholders, interacts with the article.
Interest
Rate: 15%
The 15 percent ceiling may be reduced for qualifying bank interest. Government and central-bank interest may obtain better treatment under the article.
Royalties
Rate: 15%
Royalties and fees for technical services face treaty ceilings of 10 to 20 percent depending on category and on the make-available standard for FTS.
Permanent establishment
Construction threshold: more than 120 days
Dependent-agent analysis under the treaty includes specified habitual-conclusion and stock-of-goods rules common to many India treaties.
Other treaty flags
Pension treatment is article-specific. The treaty distinguishes pensions from social-security-style payments.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1996 wording.
Article 4 reflects the 1996 wording. Residence analysis interacts with India's developing rules on Place-of-Effective-Management and Significant Economic Presence.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes a service-PE rule and specific provisions on installation and supervisory activities.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 is the operating rule for cross-border services. Its protective effect can be limited by the service-PE rule and the FTS regime in Article 12.
Article 10
Dividends
Caps source-country withholding on dividends at treaty ceilings.
Article 10 produces the 25 percent and 15 percent treaty ceilings. India's 2020 shift on dividend taxation has changed how the article applies in practice.
Article 11
Interest
Limits source-country withholding on qualifying interest.
Article 11 produces a 15 percent general ceiling. Government, central-bank, and qualifying-bank interest may obtain better treatment.
Article 12
Royalties and Fees for Technical Services
Caps royalties and FTS at treaty ceilings that vary with category.
Article 12 combines royalties and FTS at ceilings of 10 to 20 percent depending on category and on the make-available standard.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–CA treaty
- TreatyUS–IN treaty
- TreatyGB–CA treaty
- TreatyGB–IN treaty
- TreatyCA–MX treaty
- TreatyAU–CA treaty
- TreatyCA–DE treaty
- TreatyCA–FR treaty
Primary sources
- Canada Department of Finance: tax treatiesVerified 2026-05-20
- Income Tax Department of India - DTAA listVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.