Signed in 1993 and updated by a 2012 protocol, the India-UK DTAA is one of the older, more-tested treaties in India's network — and one of the more favourable, with most rates sitting below the domestic 20% India applies to non-residents by default.

The rate table

Income typeIndia-UK DTAA rateNotes
Dividends10% general, 15% for property-investment vehiclesBelow India's domestic 20% rate in the general case
Interest10% (banks/financial institutions), 15% (general)0% on government and central-bank-related interest
Royalties10% (equipment), 15% (copyright, patents, know-how)Equipment gets meaningfully better treatment than IP licensing
Fees for Technical Services (FTS)15%Applies without needing to prove a "make available" clause — broader in scope than some other Indian treaties

That last point is worth sitting with. Many of India's other DTAAs (the US treaty among them) only tax fees for technical services if the service "makes available" technical knowledge or skill the recipient can use independently afterward. The India-UK treaty's FTS provision is broader — it applies to a wider range of managerial, technical and consultancy services without that narrower test, which changes the analysis for cross-border service arrangements between the two countries.

Claiming the rate: same documentation logic as any DTAA

To access these rates instead of India's domestic 20% default, you need a Tax Residency Certificate issued by HMRC confirming UK tax residency, plus the mandatory declaration filed on India's e-filing portal (Form 10F, or its 2026 successor form depending on when you're filing — confirm the current form before you file, since India's forms have been in transition). Without this documentation in the Indian payer's hands before the payment, they withhold at the full domestic rate, and you're claiming a refund later rather than getting the benefit up front.

Capital gains sit outside the treaty cap

Unlike dividends, interest and royalties, capital gains under the India-UK DTAA are generally taxed under each country's own domestic law rather than a treaty-capped rate — there's no blanket relief here. Gains connected to air transportation and shipping contracts are a specific exception that can qualify for relief under separate treaty articles, but as a general rule, don't assume the DTAA caps your capital gains tax the way it caps withholding on dividends and interest.

Since 2020: Multilateral Instrument (MLI) modifications apply to the India-UK DTAA, adding anti-avoidance provisions that can deny treaty benefits if the main purpose of a transaction is to exploit the treaty itself — a genuine commercial rationale for the structure matters more than it used to.

Where this shows up in practice

The most common scenario we see: a UK company paying an Indian subsidiary or contractor for consulting or technical services, or an Indian company paying UK-based royalties for licensed IP or software. In both directions, the same principle holds — the treaty sets a ceiling well below India's domestic default, but only the paperwork determines whether you or the tax authority captures that difference.

For the incorporation side of setting up in the UK, see our UK company registration guide.