UK-India DTAA & NRI TaxAudited: 2026-09-11

UK-India Double Taxation Agreement: Pensions, Interest & Foreign Tax Relief 2026

Key UK-India Double Taxation Agreement rules for residents receiving pensions, interest and other Indian-source income, including Article 20 pensions, Article 12 interest, UK foreign-tax relief and India's Form 67 requirements.

Key Statutory Takeaways

✓Article 20 gives exclusive taxing rights over private pensions and annuities to the recipient's country of residence.
✓Government pensions are governed separately by Article 19 and are generally taxable only in the paying state.
✓Article 12 caps source-country withholding tax on bank and investment interest at a maximum of 15%.
✓NRO bank interest can benefit from the 15% treaty cap with a Tax Residency Certificate (TRC) and Form 10F.
✓NRE interest is tax-exempt in India under Section 10(4), but taxable in the UK for UK residents on worldwide income.
✓Form 67 is India's foreign tax credit form; UK residents claim UK foreign tax relief on HMRC SA106 Foreign pages.

Statutory Rules & Core Thresholds

In-Depth Legal Framework & Analysis

Under the UK-India Double Taxation Convention (1993, as modified by the Multilateral Instrument), non-government pensions and annuities paid to a resident of one Contracting State are taxable only in that state under Article 20. Government service pensions are reserved to the paying government state under Article 19. Under Article 12, Indian-source interest (such as NRO savings and fixed deposits) received by a UK resident is subject to a maximum Indian withholding tax of 15%, provided the taxpayer submits a UK Certificate of Residence (TRC) and Indian Form 10F. While NRE account interest is exempt from Indian income tax under Section 10(4) of the Indian Income-tax Act, UK tax residents must declare and pay UK tax on that interest under worldwide taxation rules, with foreign tax credit relief available under Article 24.

Filing Deadline & Schedule

UK Self Assessment Foreign pages (SA106) due by 31 January. Indian ITR and Form 67 due by 31 July following the Indian financial year.

Penalties & Non-Compliance

Double taxation if treaty relief or FTCR is not claimed correctly; Indian Section 206AA penal withholding (20%) if PAN/Form 10F is missing; HMRC non-declaration penalties under Schedule 24 FA 2007.

Important UK-India DTAA Articles

Article 12: InterestMax Up to 15% of gross interest for a beneficial owner resident in the other Contracting State.

Indian-source interest received by a UK resident can be taxed in India, subject to the 15% treaty limit and the agreement's conditions.

The UK can also tax the interest where the recipient is UK resident, with double-tax relief potentially available.

Article 20: Pensions and annuitiesResidence Country Only

A qualifying Indian private pension received by a UK treaty resident will generally be taxable only in the UK, while a qualifying UK private pension received by an Indian treaty resident will generally be taxable only in India.

The pension must fall within the treaty definition and must not instead be a government pension governed by Article 19.

Article 19: Governmental remuneration and pensions

Certain government pensions are generally taxable only in the paying government state, subject to the treaty conditions.

Article 24: Elimination of double taxation

India tax payable in accordance with the treaty can generally be allowed as a credit against UK tax calculated on the same Indian-source income or gains, subject to UK foreign-tax-credit rules.

Foreign tax credit relief is subject to the applicable UK credit limitation and cannot simply be assumed to equal every amount of Indian tax paid.

Indian Interest for UK Residents

Treaty Cap: 15% maximum source-country rate under Article 12 for a qualifying beneficial owner resident in the other Contracting State.
🇮🇳 NRO Account Interest

India Tax: Interest on an Indian NRO account is generally taxable in India under Indian domestic law.

Treaty Rate: A UK resident may be able to invoke the treaty's 15% maximum rate where the Article 12 conditions are met.

UK Tax: The gross interest can also be taxable in the UK for a UK tax resident, with possible credit for qualifying Indian tax.

🇮🇳 NRE Account Interest

India Tax: Qualifying NRE-account interest can be exempt from Indian income tax under Indian domestic rules, subject to the conditions for the exemption.

UK Tax: UK residence can nevertheless bring the interest within UK taxation because UK residents normally pay UK tax on foreign income.

Indian tax exemption does not automatically create a UK tax exemption.

Fixed Deposits: Indian fixed-deposit interest is generally interest income and can be subject to Indian withholding/domestic tax and UK taxation where the recipient is UK resident.

Frequently Asked Questions: UK-India Double Taxation Agreement: Pensions, Interest & Foreign Tax Relief 2026

Article 20 covers pensions and annuities. A qualifying private pension paid to a resident of one Contracting State is generally taxable only in that state. Government pensions are dealt with separately under Article 19.

Article 12 generally limits Indian source-country tax on qualifying interest beneficially owned by a UK resident to 15% of the gross interest. The recipient may still have UK tax to pay, with UK foreign-tax credit relief potentially available for qualifying Indian tax.

NRO interest is generally taxable in India under Indian domestic law. Where the recipient is a UK treaty resident and satisfies the treaty conditions, Article 12 can limit Indian source-country tax to 15%. The interest can also be taxable in the UK, with possible credit for qualifying Indian tax.

It can be. Qualifying NRE interest may be exempt from Indian tax under Indian domestic rules, but a person who is UK tax resident normally needs to consider UK tax on foreign interest. An Indian exemption does not automatically make the interest exempt in the UK.

Form 67 is used by eligible Indian resident taxpayers to claim Foreign Tax Credit for qualifying foreign tax paid outside India. It is filed online with India's Income Tax Department and is not the form used to claim UK foreign-tax credit relief.

It can allocate taxing rights and provide relief from double taxation, but the result depends on the relevant article and each country's domestic foreign-tax-credit rules. Where both countries tax the same income, the available credit is generally subject to statutory limits.
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Primary Statutory Authority

Tax Year Covered:2026/27 (6 April 2026 – 5 April 2027 (UK) / 1 April 2026 – 31 March 2027 (India))
Enacting Legislation:UK-India Double Taxation Convention 1993 (SI 1993/1801, as modified by MLI); Income Tax Act 1961 (India s.90, s.10(4), Rule 128); TIOPA 2010 Part 2
HMRC Guidance Note:HMRC Double Taxation Relief Manual (DT9550–DT9565) & Indian CBDT Circulars on Form 67
Statutory Rates Framework:15% Article 12 Interest cap; Residence-only Article 20 Private Pensions; Article 24 Foreign Tax Credit Relief

🌐 Claiming Relief for Indian Tax in the UK

A UK resident who pays qualifying Indian tax on income or gains that are also taxable in the UK may generally claim foreign tax credit relief under UK domestic rules and the treaty.

Calculation: The credit is generally limited to the UK tax attributable to the doubly taxed income or gain.
Reporting: The Indian income and foreign tax are normally reported through the relevant UK Self Assessment foreign-income pages where a return is required.

Frequently Asked Questions

Q: Which UK-India DTAA article covers private pensions?

Article 20 covers pensions and annuities. A qualifying private pension paid to a resident of one Contracting State is generally taxable only in that state. Government pensions are dealt with separately under Article 19.

Q: What is the UK-India treaty rate for Indian interest received by a UK resident?

Article 12 generally limits Indian source-country tax on qualifying interest beneficially owned by a UK resident to 15% of the gross interest. The recipient may still have UK tax to pay, with UK foreign-tax credit relief potentially available for qualifying Indian tax.

Q: How is Indian NRO interest taxed for someone living in the UK?

NRO interest is generally taxable in India under Indian domestic law. Where the recipient is a UK treaty resident and satisfies the treaty conditions, Article 12 can limit Indian source-country tax to 15%. The interest can also be taxable in the UK, with possible credit for qualifying Indian tax.

Q: Is NRE account interest taxable in the UK?

It can be. Qualifying NRE interest may be exempt from Indian tax under Indian domestic rules, but a person who is UK tax resident normally needs to consider UK tax on foreign interest. An Indian exemption does not automatically make the interest exempt in the UK.

Q: What is Form 67 used for in India?

Form 67 is used by eligible Indian resident taxpayers to claim Foreign Tax Credit for qualifying foreign tax paid outside India. It is filed online with India's Income Tax Department and is not the form used to claim UK foreign-tax credit relief.

Q: Can the UK-India DTAA prevent double taxation completely?

It can allocate taxing rights and provide relief from double taxation, but the result depends on the relevant article and each country's domestic foreign-tax-credit rules. Where both countries tax the same income, the available credit is generally subject to statutory limits.

Common Taxpayer Misconceptions

❌ Assuming Article 18 covers pensions under the UK-India treaty

✓ Rule: Under the UK-India Convention, Article 18 governs Artistes and Athletes. Private pensions and annuities are covered by Article 20, while government pensions are covered by Article 19.

❌ Believing Indian NRO interest has an unconditional 15% rate without documentation

✓ Rule: Article 12 provides a maximum 15% source-country rate for qualifying beneficial owners. To obtain it from Indian banks, non-residents must furnish a Tax Residency Certificate (TRC) and Form 10F.

❌ Believing NRE account interest is tax-free in the UK because it is tax-free in India

✓ Rule: Qualifying NRE interest is exempt in India under domestic law, but a UK tax resident is taxable on worldwide income and must declare NRE interest on UK Self Assessment.

❌ Believing Indian Form 67 is used to claim UK foreign tax credit relief

✓ Rule: Form 67 is an Indian form for Indian residents claiming credit for foreign taxes. UK foreign tax relief is claimed on HMRC SA106 Foreign pages.