Seoul to Mumbai: Four India Changes That Matter in 2026
Your India-Korea treaty gives you 10% interest and 15% dividend caps. Unchanged. But four things on the India side shifted in 2024-26 that affect your filing and your property sales.
Seoul NRIs: what your CA missed in September 2024
India-Korea DTAA: 10% interest (Article 11), 15% dividends (Article 10). Unchanged in 2024-26.
Four India-side changes you should know:
1. **Section 148 reopening** shortened to 3 years (5 years for escaped income > ₹50L). September 2024 onwards.
2. **Faceless mandate** confirmed by Supreme Court (July 2025). Section 148 notices issued by a JAO directly are void. Check your notice.
3. **Budget 2024 LTCG** — 12.5% flat on NRI property sales, no indexation, from 23 July 2024.
4. **Black Money Act** small-asset safe harbour raised to ₹20L, September 2025.
NTS and Form 10F practicalities
Korean National Tax Service (NTS) issues tax residency certificates through the Hometax portal. The process is online and relatively quick. Your Form 10F on the Indian e-filing portal references the Korean TRC and your Korean tax ID.
The 10% interest and 15% dividend rates apply to every qualifying Indian income stream. For retail Korea NRIs with Indian FDs and dividend-paying stocks, this is straightforward recovery — no litigation, no ambiguity.
Samsung, LG, Hyundai — and the 15% dividend rate nobody in Seoul claims
Most Indians in Seoul work for chaebols. Most get their Indian dividend income from legacy portfolios managed by parents back home. And most have never filed Form 10F because the India-Korea treaty is less discussed in local NRI circles than the US or Singapore ones.
Korea's National Tax Service (NTS) issues TRCs via Hometax in a few days. Attach it to your e-filed Form 10F and you drop the interest TDS from 30% to 10% and the dividend TDS from 20% to 15% (Korea's treaty cap is 15% for individual holders).
If you also hold Korean-listed stocks through KRX and you're an Indian tax resident transitioning back, Schedule FA in your Indian ITR needs those disclosed — Korean crypto holdings too, which NTS now reports to India under CRS.
Country guides mentioned
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