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Guide · Income Tax

Section 9 — Income Deemed to
Accrue or Arise in India

When is a non-resident taxed in India? Section 9 is the deeming provision that pulls business-connection profits, indirect transfers, royalty, FTS, interest and India-service salary into the Indian tax net — even when the money is received abroad.

TaxClue Editorial Desk Updated 18 August 2026 5 min read 15 FAQs answered
Updated for AY 2026-27 Income-tax Act 2025 aligned NRI & foreign-company guide
Quick Answer

Section 9 deems certain income to "accrue or arise in India" even when it is received outside India, so a non-resident can be taxed here. It covers income from a business connection (including significant economic presence), property/assets in India, indirect transfer of Indian assets, salary for services rendered in India, and interest, royalty and fees for technical services (FTS) paid by an Indian resident. A DTAA overrides Section 9 where the treaty rate is lower — claimed with a TRC + Form 10F.

Applies to Non-residents
Royalty/FTS TDS 20%
DTAA rate 10-15%
DTAA docs TRC + 10F
1961 Act vs Income-tax Act 2025

The familiar reference is Section 9 of the Income-tax Act, 1961 — that is the search intent and it stays valid. The rewritten Income-tax Act, 2025 (effective 1 April 2026, AY 2026-27) re-enacts the same rules under Section 9 with a cleaner structure — business connection, SEP, indirect transfer, royalty/FTS and interest survive unchanged in substance. The clause labels (e.g. 9(1)(i), 9(1)(vi)) are the well-known 1961 references used below.

The seven heads

What Income Does Section 9 Deem to Arise in India?

Each head fixes an Indian tax nexus regardless of where the income is actually received. The clause numbers below are the well-known Section 9(1) sub-clauses.

Income typeClauseKey conditionTDS
Business-connection profits9(1)(i)Attributable to Indian operations / SEPs.195
Capital gains on Indian asset9(1)(i)Capital asset situated in India20% / 12.5%
Indirect transfer of Indian assets9(1)(i) Expl.5Foreign shares deriving value from Indias.195
Salary for services in India9(1)(ii)Services rendered in Indias.192 slab
Govt salary (citizen abroad)9(1)(iii)Paid by Indian Governments.192
Interest paid by Indian resident9(1)(v)Paid to non-resident (few exceptions)20%
Royalty from Indian resident/Govt9(1)(vi)IP used or usable in India20%
Fees for technical services (FTS)9(1)(vii)Services utilised in India20%

Domestic rates shown; a DTAA can reduce royalty/FTS/interest to 10-15%. Rates are before surcharge and 4% cess.

Section 9(1)(i)

Business Connection & Significant Economic Presence

A non-resident has a business connection where there is a real and intimate relationship between its business and India — the profits attributable to Indian operations are then taxable here.

  • Dependent agent who habitually concludes contracts, maintains stock, or secures orders in India creates a business connection.
  • Independent agents acting in the ordinary course, mere purchasing of goods for export, or only collecting news/information are excluded.
  • Significant Economic Presence (SEP): digital transactions above a prescribed payment threshold, or systematic soliciting of / interaction with a prescribed number of Indian users, is a business connection even without any physical presence.
  • POEM (Place of Effective Management): a foreign company effectively managed from India becomes a resident and its global income is taxable in India.
Attribution, not the whole profit

Only the profit reasonably attributable to the Indian operations is taxable under the business-connection rule — not the non-resident's entire global income. Getting the attribution and any PE position right (and the DTAA that applies) is where most disputes and TDS defaults arise.

Foreign company with an Indian agent, users or a PE? Get your business-connection and attribution position reviewed.

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Explanation 5 · the "Vodafone" rule

Indirect Transfer of Indian Assets

If a non-resident transfers shares of a foreign company that derives its value substantially from assets located in India, the gain is deemed to arise in India and is taxable here — the rule introduced to counter offshore holding structures.

Taxed

Deemed to arise in India

  • Indian assets exceed Rs 10 crore in value, and
  • They represent more than 50% of the foreign company's global assets
  • Gain computed on the India-attributable portion
vs
Exempt

Outside the net

  • Small holder: <5% shareholding and voting rights
  • Shares of a listed foreign company (subject to conditions)
  • Qualifying reorganisations / amalgamations
Indian-entity reporting duty

The Indian concern whose assets are indirectly transferred must report the transaction and furnish information to the tax department. Missing this reporting attracts penalty even where the ultimate gain is small — a common trap in cross-border M&A.

Section 195 & treaty relief

TDS on Payments to Non-Residents & DTAA Override

When you pay a Section-9 income to a non-resident, you must deduct TDS under Section 195 before remitting, and file Form 15CA/15CB. Domestic rates are steep, but a DTAA usually lowers them if the payee furnishes a Tax Residency Certificate (TRC), Form 10F and a No-PE declaration.

PaymentDomestic rateTypical DTAARequirement
Royalty20% + SC + cess10-15%TRC + Form 10F
Fees for technical services20% + SC + cess10-15%TRC + Form 10F
Interest20% + SC + cess10-12.5%TRC + Form 10F
Capital gains on shares20% STCG / 12.5% LTCGSome exemptTRC + Form 10F
Business profits (PE)Slab / corporatePer DTAAPE determination

Royalty/FTS 20% is the Section 115A rate (Finance Act 2023). Surcharge and 4% health & education cess apply on domestic rates only, not on DTAA rates. No PAN → higher rate under Section 206AA (relief if TRC/10F conditions met).

DTAA relief usually applies if

  • Payee is a tax resident of a treaty country with a valid TRC
  • Form 10F filed online and a No-PE declaration given
  • No permanent establishment in India for the income

Full domestic rate if

  • No TRC / Form 10F, or no treaty with the payee's country
  • Income is attributable to an Indian PE / business connection
  • PAN not furnished (Section 206AA) and conditions unmet
  • Determine the correct Section 9 head and clause
  • Check whether a DTAA gives a lower rate
  • Collect TRC + Form 10F + No-PE declaration
  • Deduct TDS under Section 195 and file Form 15CA / 15CB
  • Report indirect transfers where the Indian concern is involved
Government sourcesBare provision: Section 9, Income-tax Act 1961 (incometaxindia.gov.in) · Deemed income notes: incometaxindia.gov.in · e-filing portal (Form 10F / 15CA): incometax.gov.in · Re-enacted as Section 9, Income-tax Act 2025 (eff. 1 Apr 2026, AY 2026-27)
People also ask

Section 9 — Frequently Asked Questions

Basics
What does Section 9 of the Income-tax Act cover?
Section 9 is a deeming provision: it treats certain income as "accruing or arising in India" even if it is received outside India, so a non-resident can be taxed here. It covers income from a business connection in India (including significant economic presence), property or assets in India, indirect transfer of Indian assets, salary for services rendered in India, and interest, royalty and fees for technical services (FTS) paid by an Indian resident.
Does Section 9 still apply under the Income-tax Act, 2025?
Yes. The old reference is Section 9 of the Income-tax Act, 1961. The rewritten Income-tax Act, 2025 (effective 1 April 2026, AY 2026-27) re-enacts the same rules under Section 9 with a cleaner structure. Business connection, significant economic presence, indirect transfer, royalty, FTS and interest survive unchanged in substance, so the familiar 9(1)(i) to 9(1)(vii) references remain the practical guide.
Is Section 9 income taxable even if received outside India?
Yes — that is the whole point of Section 9. Once income falls within one of its heads (business connection, Indian asset, indirect transfer, India-service salary, or interest/royalty/FTS paid by an Indian resident), it is deemed to accrue in India and is taxable here regardless of where it is actually received or where the contract is signed.
Business connection
What is a "business connection" under Section 9?
A business connection exists where there is a real and intimate relationship between a non-resident's business and India — for example a dependent agent in India who habitually concludes contracts, maintains stock or secures orders. Independent agents in the ordinary course of business, purchasing goods for export, and merely collecting news or information are excluded. Only profits attributable to the Indian operations are taxed.
What is Significant Economic Presence (SEP)?
SEP is a digital-economy nexus in Section 9(1)(i). A non-resident has a business connection in India — even with no physical presence — if its transactions in goods, services or property (including data or software downloads) with Indian persons exceed a prescribed payment threshold, or if it systematically solicits business from or interacts with a prescribed number of users in India through digital means.
Does a subsidiary in India create a business connection for the parent?
Not by itself. The mere existence of an Indian subsidiary does not automatically create a business connection for the foreign parent, provided dealings are at arm's length. A business connection or permanent establishment can still arise if the subsidiary acts as a dependent agent, concludes contracts, or the foreign company is effectively managed from India (POEM).
Indirect transfer
What is indirect transfer of assets under Section 9?
Under Explanation 5 to Section 9(1)(i) (the "Vodafone" provision), if a non-resident transfers shares of a foreign company that derives its value substantially from Indian assets, the gain is deemed to arise in India. It is triggered when the Indian assets exceed Rs 10 crore in value and represent more than 50% of the foreign company's global assets.
What is exempt from the indirect-transfer rule?
Small investors holding less than 5% of the shares and voting rights (with no management/control) are outside the net, as are certain listed-foreign-company shares and qualifying reorganisations or amalgamations where no tax arises in the foreign country. Even where the gain is small, the Indian concern involved must still report the transaction to the tax department.
NRI salary
Is an NRI's salary taxable in India under Section 9?
Salary for services rendered in India is taxable in India under Section 9(1)(ii) even if paid abroad. An NRI working briefly in India is taxed proportionately on the India working days. Salary for services rendered entirely outside India, paid by a non-resident employer, is not deemed to arise in India. Salary paid by the Indian Government to an Indian citizen posted abroad is taxable under 9(1)(iii).
Is interest paid to a non-resident deemed to arise in India?
Yes. Under Section 9(1)(v), interest paid by an Indian resident (or the Government) to a non-resident is deemed to accrue in India and is taxable here, subject to a few exceptions such as interest on foreign-currency borrowing used for a business carried on outside India. It is subject to TDS under Section 195, reducible under a DTAA.
TDS & DTAA
What is the TDS rate on royalty and FTS paid to non-residents?
The domestic rate under Section 195 read with Section 115A is 20% (plus applicable surcharge and 4% health & education cess), doubled from 10% by the Finance Act 2023. A DTAA usually reduces royalty and FTS to 10-15% where the non-resident furnishes a Tax Residency Certificate, Form 10F and a No-PE declaration.
How does a DTAA override Section 9?
A non-resident can choose whichever of the domestic law or the DTAA is more beneficial. If the treaty rate on royalty, FTS or interest is lower than the domestic 20%, the treaty applies — provided the payee gives a valid TRC, files Form 10F online and, where relevant, a No-PE declaration. Surcharge and cess are not added on top of DTAA rates.
What is Form 15CA / 15CB and when is it needed?
Before remitting most Section-9 payments to a non-resident, the payer files Form 15CA (a self-declaration) and, above prescribed thresholds, Form 15CB (a chartered accountant's certificate confirming the correct TDS and treaty position). They ensure tax is deducted before money leaves India and are filed on the income-tax e-filing portal.
What happens if the non-resident has no PAN?
Under Section 206AA, absence of PAN generally forces a higher TDS rate. However, relief is available for non-residents on royalty, FTS, interest and similar payments if they furnish the prescribed details — name, address, country, TRC and Tax Identification Number — so that the DTAA rate can still apply without a PAN.
Do capital gains of a non-resident fall under Section 9?
Yes. Gains on transfer of a capital asset situated in India (or an indirect transfer) are deemed to arise in India. After 23 July 2024, listed-equity STCG under Section 111A is 20% and LTCG under Section 112A is 12.5% (with the annual Rs 1.25 lakh exemption). Some DTAAs exempt or reduce capital-gains tax, subject to TRC and treaty conditions.
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