Treaty detail
United Kingdom - India tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1993-10-25
Effective
1993-12-25
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 10%
The lower 10 percent corporate rate generally depends on a direct-ownership threshold. India's domestic dividend regime, modified in 2020 to shift the tax to shareholders, interacts materially with the article.
Interest
Rate: 15%
The 15 percent general ceiling can be reduced to 10 percent for qualifying bank interest, and government and central-bank interest may obtain better treatment.
Royalties
Rate: 15%
Royalties and fees for technical services generally face ceilings of 10 to 15 percent depending on category. The treaty includes a fees-for-technical-services regime parallel to royalties.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis remains important under the treaty and includes specified habitual-conclusion and stock-of-goods wording.
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 1993 wording as amended by the 2013 protocol.
Article 4 has been amended by protocol. Residence analysis under the treaty interacts with India's developing rules on Place-of-Effective-Management and on Significant Economic Presence (SEP).
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes a service-PE rule that can create a permanent establishment based on the furnishing of services beyond a defined number of days. The classic construction-site threshold also applies.
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 in Article 5 and by the fees-for-technical-services regime in Article 13.
Article 10
Dividends
Caps source-country withholding on dividends with rates that vary with shareholding.
Article 10 produces the 15 percent and 10 percent ceilings. India's 2020 shift from dividend distribution tax to shareholder-level taxation has changed how the article applies in practice.
Article 11
Interest
Limits source-country withholding on qualifying interest with category-specific rates.
Article 11 produces the 15 percent general ceiling but allows 10 percent for qualifying bank interest and zero treatment for government and central-bank interest.
Article 13
Royalties and Fees for Technical Services
Caps royalties and FTS at treaty ceilings that vary with category.
Article 13 combines royalties and fees for technical services. The FTS provision is one of the most-litigated articles in the India context because of the 'make-available' standard and category-by-category classification questions.
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–GB treaty
- TreatyUS–IN treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
Primary sources
- HMRC: India tax treatyVerified 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.