DTAA · double-taxation treaties — how the US / UK / UAE treaties keep you from being taxed twice

What is DTAA?

Double Taxation Avoidance Agreement — bilateral treaties between India and 90+ countries that prevent the same income being taxed in both countries. India has DTAAs with the US, UK, UAE, Canada, Australia, Singapore, Germany — basically every meaningful diaspora destination.

How DTAA works in practice

Two methods:

• Exemption method: One country exempts the income (rare; mostly UAE).
• Tax credit method (most common): You pay tax in the source country, then get a credit against tax owed in your residence country. Net: you pay the higher of the two rates, not both.

Common scenarios

• NRI in US with NRO interest: India deducts 30% TDS on NRO interest. As US tax resident, you can either claim DTAA-reduced rate of 15% (file Form 10F + tax residency certificate) or pay 30% in India and claim Foreign Tax Credit on US 1040.
• NRI in UAE selling Indian property: 20% LTCG in India; UAE has no income tax, so this is your effective rate.
• NRI in UK with Indian salary: India taxes the salary; UK as residence country gives FTC up to UK rate.

The paperwork

To claim DTAA benefits in India:

• Form 10F — annual self-declaration of foreign tax residency
• Tax Residency Certificate — issued by your foreign tax authority (US: IRS Form 6166)
• PAN — Indian tax ID, mandatory