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International Tax

NRI Taxation Under Income Tax Act 2025: Complete Guide for Non-Residents

VS Vikas Sharma 📅 March 26, 2026 ⏱️ 5 min read 👁️ 0 views

Key Highlights

  • NRI status determined under Section 6, ITA 2025 (less than 182 days in India)
  • NRIs taxed only on Indian-source income — not global income
  • Higher TDS rates on NRI income: 20-30% on most investment income
  • DTAA (Double Tax Avoidance Agreement) can reduce TDS — requires Tax Residency Certificate (TRC)
  • NRE account interest: Exempt while NRI/RNOR; taxable once ROR
  • NRO account interest: Taxable with 30% TDS
  • NRI returning to India: RNOR status gives 2-3 years of foreign income exemption
  • Special rates under Chapter XIII-E for NRI investment income

1. Overview

An NRI (Non-Resident Indian) is taxed in India only on income that arises in India, is deemed to arise in India, or is received in India. Their foreign income — salary earned abroad, foreign bank interest, overseas capital gains — is not taxable in India. This contrasts with Resident and Ordinarily Resident (ROR) taxpayers who are taxed on global income.

Legal Reference
Section 6 (Residential Status), Section 5 (Scope of Income), Sections 213–229 (Chapter XIII-E — Special Provisions for NRI), Income Tax Act, 2025 | DTAA provisions apply per respective bilateral agreements

2. NRI Status Under ITA 2025

You are an NRI (Non-Resident) for a Tax Year if you do NOT satisfy either of these conditions:

  • Present in India for 182 days or more during the Tax Year, OR
  • Present in India for 60 days or more in current year AND 365 days or more in preceding 4 years

Modified rules for Indian citizens and PIOs visiting India — the 60-day threshold becomes 120 days if Indian income exceeds ₹15 lakh.

Deemed residency rule (Section 6(1A)): An Indian citizen not liable to tax anywhere else with Indian income >₹15 lakh is deemed Resident in India even if below 182 days.

3. What Income is Taxable for NRIs?

Income TypeTaxable in India for NRI?
Salary for services rendered in IndiaYes — slab rates
Salary credited to Indian account by foreign employerYes — received in India
Rent from property in IndiaYes — arises in India
Capital gains from sale of Indian shares/propertyYes — arises in India
Dividend from Indian companyYes — 20% TDS (Chapter XIII-E)
Interest on NRO accountsYes — 30% TDS
Interest on NRE accountsNo — exempt while NRI/RNOR
Foreign salary earned abroadNo — not Indian source
Foreign bank interestNo — not Indian source

4. Special Tax Rates for NRIs (Chapter XIII-E)

Income TypeTDS RateSection (ITA 2025)
NRO FD interest30% + surcharge + cessSection 393 / Chapter XIII-E
Dividend from Indian company20%Section 213
LTCG on Indian equity (listed)12.5% (above ₹1.25L)Section 195
STCG on Indian equity (listed)20%Section 196
LTCG on immovable property12.5%Section 195
Rental income30% (as per Section 196)TDS by tenant
Royalties and fees for technical services20% (or DTAA rate)Section 396

5. DTAA Benefits: Reducing TDS

India has Double Tax Avoidance Agreements (DTAAs) with 90+ countries including USA, UK, UAE, Canada, Australia, Singapore, and Germany. Under a DTAA, NRIs can pay lower TDS rates than the statutory rates under ITA 2025.

To claim DTAA benefits:

  1. Obtain a Tax Residency Certificate (TRC) from the country of residence
  2. Submit Form 10F to the deductor (payer in India)
  3. Ensure the deductor applies DTAA rate instead of standard TDS rate
  4. File Form 67 in ITR to claim any foreign tax credit for taxes already paid abroad
UAE NRI Alert
The UAE has no income tax, so UAE-based Indian citizens get no DTAA benefit for UAE taxes. But India-UAE DTAA can still help — for example, restricting India's taxation of certain income. Always verify the specific DTAA provisions with a tax advisor.

6. RNOR Status: The Returning NRI Benefit

When an NRI returns to India, they typically qualify as RNOR (Resident but Not Ordinarily Resident) for 2–3 years — during which foreign income is NOT taxable in India. This transition window is valuable for:

  • Liquidating foreign assets while still RNOR — gains not taxable
  • Converting NRE FDs to resident FDs without immediate tax hit on accumulated interest
  • Planning the transition of global income to India

RNOR conditions: Resident but NR in 9 of preceding 10 Tax Years, OR present in India ≤ 729 days in preceding 7 years.

7. NRI Selling Property in India: TDS Rules

When an NRI sells immovable property in India, the buyer must deduct TDS on the sale consideration (not just on capital gains):

  • Long-term capital gains: 12.5% on full sale consideration (or application for lower TDS certificate)
  • Short-term: 30% on full consideration
  • The NRI can apply for a Certificate under Section 238 of ITA 2025 for nil/lower TDS deduction (based on actual capital gains calculation)
  • TDS deposit: within 30 days from end of month of deduction

8. NRI ITR Filing Obligations

  • Must file ITR if Indian income exceeds basic exemption (₹4 lakh under new regime)
  • No age-based enhanced exemption for NRIs — same ₹4 lakh regardless of age
  • No Section 157 rebate available (NRIs cannot claim Section 157)
  • Schedule FA (foreign assets) disclosure NOT required for NRIs — only for ROR taxpayers
  • DTAA benefits must be claimed in ITR with TRC and Form 10F

9. Latest Updates Under ITA 2025

  • NRI provisions now in Chapter XIII-E (Sections 213–229) replacing scattered old sections
  • Deemed residency rule (₹15L threshold) retained from Finance Act 2020
  • 120-day rule for Indian citizens visiting India with >₹15L Indian income retained
  • DTAA override provisions continue under Section 162 (GAAR exceptions)

10. Why TaxClue

NRI taxation involves residential status determination, TDS compliance for Indian income, DTAA planning, and RNOR transition strategy. TaxClue's NRI tax specialists handle complete NRI tax compliance — from residential status advisory to ITR filing and foreign tax credit claims. Contact us for NRI tax planning and filing.

11. Resources & Checklist

  • ☐ Determine residential status using passport and day-count analysis
  • ☐ Check deemed residency rule if Indian income >₹15 lakh
  • ☐ Obtain TRC from country of residence for DTAA benefits
  • ☐ Submit Form 10F to all Indian deductors
  • ☐ File ITR if Indian income >₹4 lakh
  • ☐ Claim foreign tax credit via Form 67 in ITR
  • ☐ Plan RNOR window before returning to India permanently

12. Contact Us

NRI tax compliance is complex but manageable with the right advisor. Contact us for complete NRI tax services under the Income Tax Act, 2025.

Disclaimer
This article is for general informational and educational purposes only. It does not constitute legal, financial, or professional tax advice. Readers are advised to consult a qualified Chartered Accountant or tax professional before making any decisions. TaxClue Consultech Pvt Ltd accepts no liability. All case studies and examples are illustrative only.

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❓ Frequently Asked Questions
What income is taxable for NRIs under the Income Tax Act, 2025?
NRIs under the Income Tax Act, 2025 are taxed only on income that arises in India, is deemed to arise in India, or is received in India. This includes: salary for services rendered in India, rent from Indian property, capital gains from Indian shares or property, dividend from Indian companies, and interest on NRO accounts. Foreign salary, foreign bank interest, and overseas capital gains are not taxable in India for NRIs.
What is the TDS rate on NRO account interest?
Interest earned on NRO (Non-Resident Ordinary) accounts is taxable in India and subject to TDS at 30% plus applicable surcharge and health & education cess. This is deducted directly by the bank. NRIs can claim a lower TDS rate by invoking the applicable DTAA between India and their country of residence — this requires submitting a Tax Residency Certificate (TRC) and Form 10F to the bank.
Can NRIs claim the Section 157 tax rebate?
No. The Section 157 rebate (equivalent to old Section 87A — zero tax up to ₹12 lakh) is available only to Resident individuals. Non-Resident Individuals (NRIs) cannot claim this rebate even if their total Indian income is below ₹12 lakh. Similarly, NRIs do not get the age-based higher basic exemption available to senior citizens under the old tax regime — the basic exemption for NRIs is ₹4 lakh (new regime) regardless of age.
What is RNOR status and how does it help returning NRIs?
RNOR (Resident but Not Ordinarily Resident) is a transitional tax status for returning NRIs. An RNOR is technically resident in India but still exempt from tax on foreign-source income that is not derived from a business controlled from India. RNOR status typically lasts 2-3 years after return. During this period, returning NRIs can liquidate foreign assets, earn foreign income, and keep foreign bank interest without Indian tax liability — providing valuable time to restructure global finances.
What is the TDS rate for NRI selling property in India?
When an NRI sells immovable property in India, the buyer must deduct TDS on the entire sale consideration (not just the capital gain): 12.5% if the property is a long-term capital asset (held more than 24 months), or 30% for short-term capital assets. To avoid excessive TDS, the NRI can apply for a nil or lower deduction certificate under Section 238 of the Income Tax Act, 2025 by computing the actual capital gain and demonstrating the correct tax liability to the Assessing Officer.

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