The Ministry of Finance (Department of Revenue) has notified the Agreement and Protocol between the Republic of India and the State of Qatar for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income.
The agreement was signed in New Delhi on February 18, 2025, and entered into force on September 10, 2025, following completion of ratification procedures in both countries. This notification gives the agreement legal effect in India under Section 90(1) of the Income-tax Act, 1961.

The new DTAA replaces the earlier agreement signed on April 7, 1999, ensuring modernised provisions aligned with global standards on tax transparency, information exchange, and anti-abuse measures.

Objective: To eliminate double taxation of income and prevent fiscal evasion between India and Qatar while promoting economic cooperation and investment flows.

 Scope of Application:

• Applies to residents of one or both Contracting States (India and Qatar).
• Covers income-tax in India and taxes on income in Qatar, including identical or substantially similar taxes introduced later.

Entry into Force and Effective Date:

• Entered into force on September 10, 2025.
• Applicable for income arising on or after April 1, 2026 (the first day of the fiscal year following the year of entry into force).

Key Provisions:

• Permanent Establishment (PE): Defined to include offices, branches, factories, construction sites (lasting more than six months), and service PEs exceeding 90 days.
• Dividends, Interest, and Royalties:
  • Dividends – Tax capped at 5% (for ≥25% shareholding) or 10% in other cases.
  • Interest and royalties – Tax capped at 10% of gross amount.
• Business Profits: Taxable in the source country only if there is a PE; profits attributable to the PE may be taxed there.
• Capital Gains: Taxation rights clarified; gains from immovable property or shares deriving over 50% of their value from immovable property may be taxed in the source country.
• Exchange of Information & Assistance: Expands administrative cooperation for preventing tax evasion and collecting cross-border tax claims, including banking and financial data sharing.
• Principal Purpose Test (PPT): Anti-abuse clause denying treaty benefits if obtaining them was a principal purpose of any arrangement or transaction.
• Non-Discrimination: Equal tax treatment for nationals and enterprises of both countries.
• Mutual Agreement Procedure (MAP): Enables resolution of tax disputes through competent authorities of both countries.

Protocol Addition:
Clarifies that under Article 11 (Interest), the term “State” includes—

• For India: Reserve Bank of India and Export-Import Bank of India.
• For Qatar: Qatar Investment Authority and Qatar Holding LLC.