The India-Qatar DTAA Just Got Its First Full Rewrite Since 1999.

The revised India-Qatar DTAA was signed on 18 February 2025. CBDT notified it on 24 October 2025 (Notification 154/2025), and it enters into force in India from 1 April 2026.

Until 31 March 2026, the old 1999 treaty still governs. From 1 April 2026, the new treaty replaces it entirely. If you're filing FY 2025-26 returns, use the old rates. For FY 2026-27 onwards, the new rates apply.

**Dividends (Article 10):** 5% if the beneficial owner is a company holding at least 25% of the capital of the paying company. 10% in all other cases. Retail Qatari-Indian investors with small Indian stock holdings fall into the 10% bucket.

**Interest (Article 11):** 10%. Same as the old treaty. No change for FD interest, NRO savings, or bond income.

**Royalties and Fees for Technical Services (Article 12):** 10%. This is a meaningful cap. The old treaty was less clear on FTS, which caused interpretation disputes. Now it's explicit.

**Capital gains (Article 13):** Source-country taxation for shares, property, and business assets. Qatar doesn't tax capital gains domestically, so Qatari NRIs still pay the India rate — 12.5% on equity LTCG post-Budget 2024.

The new treaty includes a Principal Purpose Test (PPT) aligned with BEPS Action 6. In plain English: if the main purpose of an arrangement is to get a treaty benefit, the benefit can be denied.

For a retail Qatari-Indian NRI with Indian FDs and mutual funds, this doesn't change anything. You're using the treaty for its intended purpose — avoiding double tax on ordinary investment income.

It matters if you're routing a business or investment through a Qatari entity purely to grab a better rate. If the structure has no economic substance in Qatar, the PPT can knock it out. That's a corporate and HNI concern, not a salaried-NRI concern.

**Update your bank and AMC forms.** Your Form 10F on file probably cites the old 1999 treaty articles. Ask your Indian bank and mutual fund house to update the Form 10F and attach a fresh TRC from the Qatar General Tax Authority so the new rates kick in from 1 April 2026.

**Get a current TRC.** The Qatar GTA issues TRCs valid for the tax year. If you haven't applied in 2026, apply now so you're ready for the FY 2026-27 filing window.

**Check your AY 2025-26 filing.** You file that return under the old treaty. If you missed claiming treaty rates for the current year, you can still file a revised return or rectification under Section 154 to capture the benefit before moving to the new regime next year.

**Past-year recovery.** The old India-Qatar DTAA is still live for past years. If you never claimed DTAA benefits, you can file condonation of delay under Section 119(2)(b) for up to 6 years back, using the old treaty rates. We handle this end-to-end.