Agreement and Protocol between the India and Qatar for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income
Ministry of Finance vide Notification No. G.S.R. 789(E) / CBDT Notification No. 154/2025 dated 24.10.2025 has notified agreement and Protocol between the Republic of India and the State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
The Ministry of External Affairs of India reported in early 2025 that there were 836,784 Indians residing in Qatar. This includes both Non-Resident Indians and Persons of Indian Origin. It is estimated that Indians constitute approximately 25% of Qatar’s total population.
The said Agreement and Protocol comes into force on the 10th day of September, 2025 in accordance with paragraph 2 of Article 30 of the said Agreement and Protocol. It provides that the provisions of the Agreement and Protocol shall have effect in India in respect of income arising on or after first day of the fiscal year immediately following the calendar year in which the Agreement and Protocol enter into force.
The Agreement shall apply to persons who are residents of one or both of the Contracting States. Under the Agreement, income derived by or through an entity or arrangement that is established in either Contracting State and that is treated as wholly fiscally transparent under the tax law of either Contracting State shall be considered to be income of a resident of a Contracting State only to the extent that the income is treated, for the purposes of taxation by that State, as the income of a resident of that State.
The Agreement shall apply to all taxes imposed on total income (i.e. income from immovable property, Business Income, Shipping & Air Transport, Dividends, Interest, Royalties & Fee for Technical Services, Capital Gains, Students & Apprentices etc.) or on elements of income, including taxes on gains from the alienation of movable or immovable property and taxes on the total amounts of wages or salaries paid by enterprises imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
Where a resident of the State of Qatar derives income which, in accordance with the provisions of this Agreement, may be taxed in India, the State of Qatar shall allow as a deduction from the tax on the income of that resident an amount equal to the income-tax paid in India. Such amount shall not, however, exceed that part of the income-tax as computed before the deduction is given, which is attributable to the income which may be taxed in India. Where a resident of India derives income which, in accordance with the provisions of this Agreement, may be taxed in the State of Qatar, India shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in the State of Qatar. Such amount shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable to the income which may be taxed in the State of Qatar. Where in accordance with any provision of this Agreement income derived by a resident of India is exempt from tax in India, India may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
Further, the Agreement provides that the competent authorities of the Contracting States shall exchange such information (including documents and certified copies of documents), as is relevant for carrying out the provisions of this Agreement or to the administration and enforcement of the domestic laws of the Contracting States concerning taxes covered by the Agreement of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities insofar as the taxation thereunder is not contrary to the Agreement in particular for the prevention of fraud or evasion of such taxes.
The Contracting States also undertake to lend assistance to each other in the collection of taxes to which this Agreement relates, together with interest, costs, and civil penalties relating to such taxes, referred to in this Article as a revenue claim.
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