New Delhi, October 24, 2025 – The Ministry of Finance has officially notified the new Double Taxation Avoidance Agreement (DTAA) and Protocol between the Republic of India and the State of Qatar, paving the way for enhanced economic cooperation and clear tax guidelines.

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Agreement Details and Entry into Force

The landmark Agreement and Protocol were signed in New Delhi on the 18th day of February, 2025. The notification confirms that the DTAA officially entered into force on September 10, 2025, in accordance with Article 30.

For application, the provisions of the Agreement shall have effect in India and Qatar in respect of income arising on or after the first day of the fiscal year immediately following the calendar year in which the Agreement enters into force. Since the entry into force was in 2025, the new DTAA provisions will be effective from the fiscal year commencing in 2026.

The new Agreement supersedes the previous DTAA signed between the two nations on April 7, 1999.

Key Withholding Tax Rate Changes

The new DTAA introduces specific maximum rates for taxation on certain incomes arising in one Contracting State and paid to a resident of the other. The primary objective is the avoidance of double taxation and the prevention of fiscal evasion.

Dividends (Article 10)

Dividends may be taxed in the State of source, but the tax charged shall not exceed:

• 5 per cent of the gross amount of the dividends if the beneficial owner is a company owning at least twenty-five per cent of the shares of the company paying the dividend.
• 10 per cent of the gross amount of the dividends in all other cases.

Significantly, dividends paid to the State itself, a political subdivision, or a local authority of the other Contracting State shall be taxable only in that other State, providing a full exemption from source country tax.

Interest (Article 11) and Royalties/FTS (Article 12)

The source-country tax on interest and on royalties or fees for technical services (FTS) is capped:

• Interest: The tax shall not exceed 10 per cent of the gross amount. A full exemption applies if the beneficial owner is the State itself, a political subdivision or a local authority thereof.
• Royalties and FTS: The tax shall not exceed 10 per cent of the gross amount. The definition of “fees for technical services” includes payments for managerial, technical, or consultancy services.

The Protocol specifically clarifies that the term “State” for the purpose of the interest exemption includes the Reserve Bank of India and the Export Import Bank of India for India, and the Qatar Investment Authority and Qatar Holding LLC for Qatar.

Permanent Establishment and Capital Gains

Permanent Establishment (PE)

The definition of “permanent establishment” has been updated. A building site, construction, installation, or assembly project constitutes a PE only if it lasts more than six months.

A Services PE is constituted if the furnishing of services (including consultancy) continues for a period or periods aggregating more than 90 days within any 12-month period.

Capital Gains (Article 13)

Gains derived from the alienation of shares deriving more than 50% of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other state.

Gains from the alienation of shares (other than immovable property-rich shares) in a company which is a resident of a Contracting State may be taxed in that State.

Anti-Abuse and Dispute Resolution

The DTAA includes an Entitlement to Benefits article (Article 28), stating that a benefit shall not be granted if it is reasonable to conclude that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted in the benefit.

The Agreement also mandates robust provisions for the Mutual Agreement Procedure, Exchange of Information, and Assistance in Collection of Taxes, strengthening the cooperation between the competent authorities of both nations.

The Government of the Republic of India and the Government of the State of Qatar,
desiring to conclude an Agreement for the avoidance of double taxation and the prevention of
fiscal evasion with respect to taxes on income and with a view to promoting economic
cooperation between the two countries,

intending to eliminate double taxation with respect to the taxes covered by this Agreement
without creating opportunities for non-taxation or reduced taxation through tax evasion or
avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs
provided in this agreement for the indirect benefit of residents of third jurisdictions);
have agreed as follows:

1. This Agreement shall apply to persons who are residents of one or both of the Contracting
   States.
2. For the purposes of this 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.

1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or
   of its political subdivisions or local authorities, irrespective of the manner in which they are
   levied.
2. There shall be regarded as taxes on income all taxes imposed on total income, 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.
3. The existing taxes to which the Agreement shall apply are in particular:
   1. In India, the income-tax, including any surcharge thereon,
      (hereinafter referred to as “Indian tax”).
   2. In Qatar, taxes on income,
      (hereinafter referred to as “Qatari Tax”);
4. The Agreement shall apply also to any identical or substantially similar taxes which are
   imposed after the date of signature of the Agreement in addition to, or in place of, the
   existing taxes referred to in paragraph 3. The competent authorities of the Contracting
   States shall notify each other of any significant changes which have been made in their
   respective taxation laws.

1. For the purposes of this Agreement, unless the context otherwise requires:
   1. 1. the term “India” means the territory of India and includes the territorial sea and
         airspace above it, as well as any other maritime zone in which India has sovereign
         rights, other rights and jurisdiction, according to the Indian law and in accordance
         with international law, including the U.N. Convention on the Law of the Sea;
      2. the term “Qatar” means the State of Qatar and when used in the geographical sense
         it means the State of Qatar’s lands, internal waters, territorial sea including its bed
         and subsoil, the air space over them, the exclusive economic zone and the
         continental shelf, over which the State of Qatar exercises sovereign rights and
         jurisdiction in accordance with the provisions of international law and Qatar’s
         national laws and regulations;
      3. the term “person” includes an individual, a company, a body of persons and
         any other entity which is treated as a taxable unit under the taxation laws in force
         in the respective Contracting States;
      4. the term “company” means any body corporate or any entity which is treated as a
         body corporate for tax purposes;
      5. the terms “enterprise of a Contracting State” and “enterprise of the other Contracting
         State” mean respectively an enterprise carried on by a resident of a Contracting State
         and an enterprise carried on by a resident of the other Contracting State;
      6. the term “international traffic” means any transport by a ship or aircraft operated by
         an enterprise of a Contracting State, except when the ship or aircraft is operated
         solely between places in the other Contracting State;
      7. the term “competent authority” means :
         1. in India: the Finance Minister, Government of India, or his authorized representative
         2. in Qatar : the Minister of Finance, or his authorized representative;
      8. the term “national” means :
         1. any individual possessing the nationality of a Contracting State;
         2. any legal person, partnership or association deriving its status as such from the laws
            in force in a Contracting State;
      9. the term “fiscal year” means :
         1. in the case of India, the financial year beginning on the 1st day of April;
         2. in the case of Qatar, taxable year as defined in Qatar Income Tax Law;
      10. the term “tax” means Indian tax or Qatari tax, as the context requires, but shall not include
          any amount which is payable in respect of any default or omission in relation to the taxes

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   to which this Agreement applies or which represents a penalty or fine imposed relating to
   those taxes;

   1. the terms “Contracting State” and “the other Contracting State” mean the Republic of India
      or the State of Qatar as the context requires.
2. As regards the application of the Agreement at any time by a Contracting State, any term not
   defined therein shall, unless the context otherwise requires, have the meaning that it has at that
   time under the law of that State for the purposes of the taxes to which the Agreement applies
   and any meaning under the applicable tax laws of that State prevailing over a meaning given
   to the term under other laws of that State.

1. For the purposes of this Agreement, the term “resident of a Contracting State” means any
   person who, under the laws of that State, is liable to tax therein by reason of his domicile,
   residence, place of management or any other criterion of a similar nature, and also includes
   that State and any political subdivision, local authority or statutory body thereof. This term,
   however, does not include any person who is liable to tax in that State in respect only of income
   from sources in that State.
2. Where by reason of the provisions of paragraph 1 an individual is a resident of both
   Contracting States, then his status shall be determined as follows:
   1. he shall be deemed to be a resident only of the State with which his personal and economic
      relations are closer (centre of vital interests);
   2. if the State in which he has his centre of vital interests cannot be determined, he shall be
      deemed to be a resident only of the State in which he has an habitual abode;
   3. if he has an habitual abode in both States or in neither of them, he shall be deemed to be
      a resident only of the State of which he is a national;
   4. if he is a national of both States or of neither of them, the competent authorities of the
      Contracting States shall settle the question by mutual agreement.
3. Where by reason of the provisions of paragraph 1, a person ,other than an individual, is a
   resident of both Contracting States, the competent authorities of the Contracting States shall
   endeavour to determine by mutual agreement the Contracting State of which such person shall
   be deemed to be a resident for the purposes of the Agreement, having regard to its place of
   effective management, the place where it is incorporated or otherwise constituted and any other
   relevant factors. In the absence of such agreement, such person shall not be entitled to any relief
   or exemption from tax provided by this Agreement except to the extent and in such manner as
   may be agreed upon by the competent authorities of the Contracting States.

1. 1. For the purposes of this Agreement, the term “permanent establishment” means a fixed place
      of business through which the business of an enterprise is wholly or partly carried on.
   2. The term “permanent establishment” includes especially:
      1. a place of management;
      2. a branch;
      3. an office;
      4. a factory;
      5. a workshop;
      6. a mine, an oil or gas well, a quarry or any other place of extraction of natural resources;
      7. a sales outlet;
      8. a warehouse in relation to a person providing storage facilities for others; and
      9. a farm, plantation or other place where agricultural, forestry, plantation or related
         activities are carried on.
   3. 1. A building site or a construction, installation or assembly project or supervisory activities
         in connection therewith constitutes a permanent establishment only if such site, project or
         activity lasts more than six months;
      2. The furnishing of services, including consultancy services, by an enterprise through
         employees or other personnel engaged by the enterprise for such purpose, constitutes a
         permanent establishment only where activities of that nature continue (for the same or
         connected project) within the country for a period or periods aggregating more than 90 days
         within any 12-month period.
   4. An enterprise shall be deemed to have a permanent establishment in a Contracting State and
      to carry on business through that permanent establishment if it provides services or facilities in
      connection with, or supplies plant and machinery on hire used for or to be used in the
      prospecting for, or extraction or exploitation of mineral oils in that State.
   5. Notwithstanding the preceding provisions of this Article, the term “permanent
      establishment” shall be deemed not to include:
      1. the use of facilities solely for the purpose of storage or display of goods or merchandise
         belonging to the enterprise;
      2. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for
         the purpose of storage, or display;

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1. 1. 3. the maintenance of a stock of goods or merchandise belonging to the enterprise solely for
         the purpose of processing by another enterprise;
      4. the maintenance of a fixed place of business solely for the purpose of purchasing goods
         or merchandise or of collecting information, for the enterprise;
      5. the maintenance of a fixed place of business solely for the purpose of carrying on, for the
         enterprise, any other activity;
      6. the maintenance of a fixed place of business solely for any combination of activities
         mentioned in sub-paragraphs (a) to (e),

provided that such activity or, in the case of subparagraph f), the overall activity of the fixed
place of business, is of a preparatory or auxiliary character.

1. 5.1 Paragraph 5 shall not apply to a fixed place of business that is used or maintained by an
   enterprise if the same enterprise or a closely related enterprise carries on business activities at
   the same place or at another place in the same Contracting State and
   1. that place or other place constitutes a permanent establishment for the enterprise or
      the closely related enterprise under the provisions of this Article, or
   2. the overall activity resulting from the combination of the activities carried on by the
      two enterprises at the same place, or by the same enterprise or closely related
      enterprises at the two places, is not of a preparatory or auxiliary character,

   provided that the business activities carried on by the two enterprises at the same place, or by
   the same enterprise or closely related enterprises at the two places, constitute complementary
   functions that are part of a cohesive business operation.

2. Notwithstanding the provisions of paragraphs 1 and 2, where a person – other than an agent
   of an independent status to whom paragraph 8 applies – is acting in a Contracting State on
   behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a
   permanent establishment in the first-mentioned Contracting State in respect of any activities
   which that person undertakes for the enterprise, if such a person:
   1. has and habitually exercises, in that State an authority to conclude contracts in the name of
      the enterprise, unless the activities of such person are limited to those mentioned in paragraph
      5 which, if exercised through a fixed place of business, would not make this fixed place of
      business a permanent establishment under the provisions of that paragraph; or
   2. has no such authority, but habitually maintains in the first-mentioned State a stock of goods
      or merchandise from which he regularly delivers goods or merchandise on behalf of the
      enterprise; or
   3. habitually secures orders in the first-mentioned State, wholly or almost wholly for the
      enterprise itself or for the enterprise and other enterprises controlling, controlled by, or subject
      to the same control, as that enterprise.
3. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a
   Contracting State shall, except in regard to re-insurance, be deemed to have a permanent

establishment in the other Contracting State if it collects premiums in the territory of that other
State or insures risks situated therein through a person other than an agent of an independent
status to whom paragraph 8 applies.

8. An enterprise shall not be deemed to have a permanent establishment in a Contracting State
   merely because it carries on business in that State through a broker, general commission agent
   or any other agent of an independent status, provided that such persons are acting in the
   ordinary course of their business. However, when the activities of such an agent are devoted
   wholly or almost wholly on behalf of that enterprise or one or more enterprises to which it is
   closely related and conditions are made or imposed between that enterprise and the agent in
   their commercial and financial relations which differ from those which would have been made
   between independent enterprises, he will not be considered an agent of an independent status
   within the meaning of this paragraph.
9. The fact that a company which is a resident of a Contracting State controls or is controlled
   by a company which is a resident of the other Contracting State, or which carries on business
   in that other State (whether through a permanent establishment or otherwise), shall not of itself
   constitute either company a permanent establishment of the other.
10. For the purposes of this Article, a person or enterprise is closely related to an enterprise
    if, based on all the relevant facts and circumstances, one has control of the other or both are
    under the control of the same persons or enterprises.In any case, a person or enterprise shall be considered to be closely related to an enterprise if
    one possesses directly or indirectly more than 50 per cent of the beneficial interests in the other
    (or, in the case of a company, more than 50 per cent of the aggregate vote and value of the
    company’s shares or of the beneficial equity interest in the company) or if another person or
    enterprise possesses directly or indirectly more than 50 per cent of the beneficial interest (or,
    in the case of a company, more than 50 per cent of the aggregate vote and value of the
    company’s shares or of the beneficial equity interest in the company) in the person and the
    enterprise or in the two enterprises.

1. Income derived by a resident of a Contracting State from immovable property (including
   income from agriculture or forestry) situated in the other Contracting State may also be taxed
   in that other State.
2. The term “immovable property” shall have the meaning which it has under the law of the
   Contracting State in which the property in question is situated. The term shall in any case

include property accessory to immovable property, livestock and equipment used in agriculture
and forestry, rights to which the provisions of general law respecting landed property apply,
usufruct of immovable property and rights to variable or fixed payments as consideration for
the working of, or the right to work, mineral deposits, sources and other natural resources;
ships, boats and aircraft shall not be regarded as immovable property.

3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or
   use in any other form of immovable property.
4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable
   property of an enterprise and to income from immovable property used for the performance of
   independent personal services.

1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless
   the enterprise carries on business in the other Contracting State through a permanent
   establishment situated therein. If the enterprise carries on business as aforesaid, the profits of
   the enterprise may also be taxed in the other State but only so much of them as is attributable
   to that permanent establishment.
2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries
   on business in the other Contracting State through a permanent establishment situated therein,
   there shall in each Contracting State be attributed to that permanent establishment the profits
   which it might be expected to make if it were a distinct and separate enterprise engaged in the
   same or similar activities under the same or similar conditions and dealing wholly
   independently with the enterprise of which it is a permanent establishment.
3. In determining the profits of a permanent establishment, there shall be allowed as deductions
   expenses which are incurred for the purposes of the business of the permanent establishment,
   including executive and general administrative expenses so incurred, whether in the State in
   which the permanent establishment is situated or elsewhere, in accordance with the provisions
   of and subject to the limitations of the tax laws of that State. However, no such deduction shall
   be allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual
   expenses) by the permanent establishment to the head office of the enterprise or any of its other
   offices, by way of royalties, fees or other similar payments in return for the use of patents,
   know-how or other rights, or by way of commission or other charges for specific services
   performed or for management, or, except in the case of banking enterprises, by way of interest
   on moneys lent to the permanent establishment. Likewise, no account shall be taken, in the
   determination of the profits of a permanent establishment, for amounts charged (otherwise than
   toward reimbursement of actual expenses), by the permanent establishment to the head office

of the enterprise or any of its other offices, by way of royalties, fees or other similar payments
in return for the use of patents, know-how or other rights, or by way of commission or other
charges for specific services performed or for management, or, except in the case of a banking
enterprise, by way of interest on moneys lent to the head office of the enterprise or any of its
other offices.

4. Insofar as it has been customary in a Contracting State to determine the profits to be
   attributed to a permanent establishment on the basis of an apportionment of the total profits of
   the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State
   from determining the profits to be taxed by such an apportionment as may be customary; the
   method of apportionment adopted shall, however, be such that the result shall be in accordance
   with the principles contained in this Article.
5. No profits shall be attributed to a permanent establishment by reason of the mere purchase
   by that permanent establishment of goods or merchandise for the enterprise.
6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent
   establishment shall be determined by the same method year by year, unless there is good and
   sufficient reason to the contrary.
7. Where profits include items of income which are dealt with separately in other Articles of
   this Agreement, then the provisions of those Articles shall not be affected by the provisions of
   this Article.

1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft
   in international traffic shall be taxable only in that State.
2. For the purposes of the preceding paragraph, the ships and aircraft in the case of the State of
   Qatar shall include United Arab Shipping Company so long as the State of Qatar owns a
   share in this company or any other air or sea transport enterprise designated by the Government
   of the State of Qatar.
3. Profits derived by a transportation enterprise which is a resident of a Contracting State from
   the use, maintenance, or rental of containers (including trailers and other equipment for the
   transport of containers) used for the transport of goods or merchandise in international traffic
   shall be taxable only in that Contracting State unless the containers are used solely within the
   other Contracting State.

4. For the purposes of this Article, interest on investments directly connected with the operation
   of ships or aircraft in international traffic shall be regarded as profits derived from the operation
   of such ships or aircraft, and the provisions of Article 11 shall not apply in relation to such
   interest.
5. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a
   joint business or an international operating agency.

1. Where:
   1. an enterprise of a Contracting State participates directly or indirectly in the management,
      control or capital of an enterprise of the other Contracting State; or
   2. the same persons participate directly or indirectly in the management, control or capital of
      an enterprise of a Contracting State and an enterprise of the other Contracting State,

   and in either case conditions are made or imposed between the two enterprises in their
   commercial or financial relations which differ from those which would be made between
   independent enterprises, then any profits which would, but for those conditions, have accrued
   to one of the enterprises, but, by reason of those conditions have not so accrued, may be
   included in the profits of that enterprise and taxed accordingly.

2. Where a Contracting State includes in the profits of an enterprise of that State – and taxes
   accordingly – profits on which an enterprise of the other Contracting State has been charged to
   tax in that other State and the profits so included are profits which would have accrued to the
   enterprise of the first mentioned State if the conditions made between the two enterprises had
   been those which would have been made between independent enterprises, then that other State
   shall make an appropriate adjustment to the amount of the tax charged therein on those profits.
   In determining such adjustment, due regard shall be had to the other provisions of this
   Agreement and the competent authorities of the Contracting States shall, if necessary consult
   each other.

1. Dividends paid by a company which is a resident of a Contracting State to a resident of the
   other Contracting State may be taxed in that other State.
2. However, such dividends may also be taxed in the Contracting State of which the company
   paying the dividends is a resident and according to the laws of that State, but if beneficial owner
   of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed:

1. 5 per cent of the gross amount of the dividends if the beneficial owner is a
   company which owns at least twenty-five per cent of the shares of the company
   paying the dividend; and
2. 10 per cent of the gross amount of the dividends in all other cases.

This paragraph shall not affect the taxation of the company in respect of the profits out of which
the dividends are paid.

3. Notwithstanding the provisions of paragraphs 1 and 2, dividends paid by a company which
   is a resident of a Contracting State shall be taxable only in the other Contracting State if the
   beneficial owner of the dividends is that other State itself, a political subdivision or a local
   authority thereof.
4. The term “dividends” as used in this Article means income from shares or other rights, not
   being debt-claims, participating in profits, as well as income from other corporate rights which
   is subjected to the same taxation treatment as income from shares by the laws of the State of
   which the company making the distribution is a resident.
5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the
   dividends, being a resident of a Contracting State, carries on business in the other Contracting
   State of which the company paying the dividends is a resident, through a permanent
   establishment situated therein, or performs in that other State independent personal services
   from a fixed base situated therein, and the holding in respect of which the dividends are paid
   is effectively connected with such permanent establishment or fixed base. In such case the
   provisions of Article 7 or Article 14, as the case may be, shall apply.
6. Where a company which is a resident of a Contracting State derives profits or income from
   the other Contracting State, that other State may not impose any tax on the dividends paid by
   the company, except insofar as such dividends are paid to a resident of that other State or insofar
   as the holding in respect of which the dividends are paid is effectively connected with a
   permanent establishment or a fixed base situated in that other State, nor subject the company’s
   undistributed profits to a tax on the company’s undistributed profits, even if the dividends paid
   or the undistributed profits consist wholly or partly of profits or income arising in such other
   State.

1. Interest arising in a Contracting State and paid to a resident of the other Contracting State
   may be taxed in that other State.

2. However, such interest may also be taxed in the Contracting State in which it arises, and
   according to the laws of that State, but if the beneficial owner of the interest is a resident of the
   other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of
   the interest.
3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State shall
   be taxable only in the other Contracting State, provided that it is derived and beneficially owned
   by that other State itself, a political subdivision or a local authority thereof.
4. The term “interest” as used in this Article means income from debt-claims of every kind,
   whether or not secured by mortgage and whether or not carrying a right to participate in the
   debtors profits, and in particular, income from government securities and income from bonds
   or debentures, including premiums and prizes attaching to such securities, bonds or debentures.
   The term also includes income from arrangements such as Islamic financial instruments where
   the substance of the underlying contract can be assimilated to a loan. Penalty charges for late
   payment shall not be regarded as interest for the purpose of this Article.
5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest,
   being a resident of a Contracting State, carries on business in the other Contracting State in
   which the interest arises, through a permanent establishment situated therein, or performs in
   that other State independent personal services from a fixed base situated therein, and the debtclaim in respect of which the interest is paid is effectively connected with such permanent
   establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case
   may be, shall apply.
6. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that
   State. Where, however, the person paying the interest, whether he is a resident of a Contracting
   State or not, has in a Contracting State a permanent establishment or a fixed base in connection
   with which the indebtedness on which the interest is paid was incurred, and such interest is
   borne by such permanent establishment or fixed base, then such interest shall be deemed to
   arise in the Contracting State in which the permanent establishment or fixed base is situated.
7. Where, by reason of a special relationship between the payer and the beneficial owner or
   between both of them and some other person, the amount of the interest having regard to the
   debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the
   payer and the beneficial owner in the absence of such relationship, the provisions of this Article
   shall apply only to the last-mentioned amount. In such case, the excess part of the payments
   shall remain taxable according to the laws of each Contracting State, due regard being had to
   the other provisions of this Agreement.

1. Royalties or fees for technical services arising in a Contracting State and paid to a resident
   of the other Contracting State may be taxed in that other State.
2. However, such royalties or fees for technical services may also be taxed in the Contracting
   State in which they arise, and according to the laws of that State, but if the beneficial owner of
   the royalties or fees for technical services is a resident of the other Contracting State, the tax
   so charged shall not exceed 10 per cent of the gross amount of the royalties or fees for technical
   services.
3. 1. The term “royalties” as used in this Article means payments of any kind received as a
      consideration for the use of, or the right to use, any copyright of literary, artistic or
      scientific work including cinematograph films or films or tapes for television or radio
      broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or
      for the use of, or the right to use, any industrial, commercial or scientific equipment, or
      for information concerning industrial, commercial or scientific experience;
   2. The term “fees for technical services” as used in this Article means payment of any kind
      in consideration for the rendering of any managerial, technical or consultancy services
      including the provision of services by technical or other personnel but does not include
      payments for services mentioned in Articles 14 and 15 of this Agreement.
4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties
   or fees for technical services being a resident of a Contracting State, carries on business in the
   other Contracting State, in which the royalties or fees for technical services arise, through a
   permanent establishment situated therein, or performs in that other State independent personal
   services from a fixed base situated therein, and the right or property in respect of which the
   royalties or fees for technical services are paid is effectively connected with such permanent
   establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case
   may be, shall apply.
5. Royalties or fees for technical services shall be deemed to arise in a Contracting State when
   the payer is a resident of that State. Where, however, the person paying the royalties or fees for
   technical services, whether he is a resident of a Contracting State or not, has in a Contracting
   State a permanent establishment or a fixed base in connection with which the liability to pay
   the royalties or fees for technical services was incurred, and such royalties or fees for technical
   services are borne by such permanent establishment, or fixed base then such royalties or fees
   for technical services shall be deemed to arise in the State in which the permanent establishment
   or fixed base is situated.

6. Where, by reason of a special relationship between the payer and the beneficial owner or
   between both of them and some other person, the amount of the royalties or fees for technical
   services having regard to the use, right or information for which they are paid, exceeds the
   amount which would have been agreed upon by the payer and the beneficial owner in the
   absence of such relationship, the provisions of this Article shall apply only to the lastmentioned amount. In such case, the excess part of the payments shall remain taxable according
   to the laws of each Contracting State, due regard being had to the other provisions of this
   Agreement.

1. Gains derived by a resident of a Contracting State from the alienation of immovable property
   referred to in Article 6 and situated in the other Contracting State may be taxed in that other
   State.
2. Gains from the alienation of movable property forming part of the business property of a
   permanent establishment which an enterprise of a Contracting State has in the other Contracting
   State or of movable property pertaining to a fixed base available to a resident of a Contracting
   State in the other Contracting State for the purpose of performing independent personal
   services, including such gains from the alienation of such a permanent establishment (alone or
   with the whole enterprise) or of such fixed base, may be taxed in that other State.
3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft
   operated in international traffic or movable property pertaining to the operation of such ships
   or aircraft shall be taxable only in that State.
4. Gains derived by a resident of a Contracting State from the alienation of shares deriving
   more than 50% of their value directly or indirectly from immovable property situated in the
   other Contracting State may be taxed in that other state.
5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company
   which is a resident of a Contracting State may be taxed in that State.
6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4
   and 5, shall be taxable only in the Contracting State of which the alienator is a resident.

1. Income derived by a resident of a Contracting State in respect of professional services or
   other activities of an independent character shall be taxable only in that State except in the
   following circumstances, when such income may also be taxed in the other Contracting State:
   1. if he has a fixed base regularly available to him in the other Contracting State for the purpose
      of performing his activities; in that case, only so much of the income as is attributable to that
      fixed base may be taxed in that other State; or
   2. if his stay in the other Contracting State is for a period or periods aggregating 183 days or
      more in any 12 month period commencing or ending in the fiscal year concerned; in that case,
      only so much of the income as is derived from his activities performed in that other State may
      be taxed in that other State.
2. The term professional services includes especially independent scientific, literary, artistic,
   educational or teaching activities as well as the independent activities of physicians, lawyers,
   engineers, architects, surgeons, dentists and accountants.

1. Subject to the provisions of Articles 16, 18, 19, 20 and 21 salaries, wages, and other similar
   remuneration derived by a resident of a Contracting State in respect of an employment shall be
   taxable only in that State unless the employment is exercised in the other Contracting State. If
   the employment is so exercised, such remuneration as is derived therefrom may be taxed in
   that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a
   Contracting State in respect of an employment exercised in the other Contracting State shall be
   taxable only in the first-mentioned State if:
   1. the recipient is present in the other State for a period or periods not exceeding in the
      aggregate 183 days in any 12 month period commencing or ending in the fiscal year concerned;
      and
   2. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other
      State; and
   3. the remuneration is not borne by a permanent establishment or a fixed base which the
      employer has in the other State.

3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of
   an employment exercised aboard a ship or aircraft operated in international traffic, by an
   enterprise of a Contracting State may be taxed in that State.
4. Notwithstanding the preceding provisions of this Article, a Contracting State shall exempt
   salaries, wages, allowances and perquisites from tax in the case of employees of a designated
   national air transport carrier of the other Contracting State provided that they are nationals of
   that other Contracting State.

Directors’ fees and other similar payments derived by a resident of a Contracting State in his
capacity as a member of the board of directors of a company which is a resident of the other
Contracting State may also be taxed in that other State.

1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a
   Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste,
   or a musician, or as a sportsperson, from his personal activities as such exercised in the other
   Contracting State, may be taxed in that other State.
2. Where income in respect of personal activities exercised by an entertainer or a sportsperson
   in his capacity as such accrues not to the entertainer or sportsperson himself but to another
   person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in
   the Contracting State in which the activities of the entertainer or sportsperson are exercised.
3. The provisions of paragraphs 1 and 2, shall not apply to income from activities performed
   in a Contracting State by entertainers or sportspersons if the activities are substantially
   supported by public funds of one or both of the Contracting States or of political subdivisions
   or local authorities thereof. In such a case, the income is taxable only in the Contracting State
   of which the entertainer or sportsperson is a resident.

Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration
paid to a resident of a Contracting State in consideration of past employment shall be taxable
only in that State.

1. 1. Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting
      State or a political subdivision or a local authority thereof to an individual in respect of services
      rendered to that State or subdivision or authority shall be taxable only in that State.
   2. However, such salaries, wages and other similar remuneration shall be taxable only in
      the other Contracting State if the services are rendered in that other State and the individual is
      a resident of that other State who:
      1. is a national of that other State; or
      2. did not become a resident of that other State solely for the purpose of rendering the services.
2. 1. Any pension paid by, or out of funds created by, a Contracting State or a political
      subdivision or a local authority thereof to an individual in respect of services rendered to that
      State or subdivision or authority shall be taxable only in that State.
   2. However, such pension shall be taxable only in the other Contracting State if the
      individual is a resident of, and a national of, that State.
3. The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration and pensions in
   respect of services rendered in connection with a business carried on by a Contracting State or
   a political subdivision or a local authority thereof.

1. A student or business apprentice who is or was a resident of a Contracting State immediately
   before visiting the other Contracting State and who is present in that other Contracting State
   solely for the purpose of his education or training shall be exempt from tax in that other State
   on, besides grants, loans and scholarships:
   1. payments made to him by persons residing outside that other State for the purposes of his
      maintenance, education or training; and
   2. remuneration from employment in that other State, provided that such employment is
      directly related to his studies or is undertaken for the purpose of his maintenance.
2. The benefits of this Article shall extend only for such period of time as may be reasonable
   or customarily required to complete the education or training undertaken, but in no event shall
   any individual have the benefits of this Article, for more than six consecutive years from the
   date of his first arrival in that other State for the purposes of his education or training.

1. A professor or teacher or research scholar who is or was a resident of the Contracting State
   immediately before visiting the other Contracting State for the purpose of teaching or engaging
   in research, or both, at a university, college, school or other approved institution in that other
   Contracting State shall be exempt from tax in that other State on any remuneration for such
   teaching or research for a period not exceeding two years from the date of his first arrival in
   that other State for that purpose.
2. This Article shall not apply to income from research, if such research is undertaken primarily
   for the private benefit of a person or persons.
3. For the purposes of this Article and Article 20, an individual shall be deemed to be a resident
   of a Contracting State if he is resident in that State in the fiscal year in which he visits the other
   Contracting State or in the immediately preceding fiscal year.
4. For the purposes of paragraph 1, approved institution means an institution which has been
   approved in this regard by the competent authority of the concerned State.

1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the
   foregoing Articles of this Agreement shall be taxable only in that State.
2. The provisions of paragraph 1 shall not apply to income, other than income from immovable
   property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident
   of a Contracting State, carries on business in the other Contracting State through a permanent
   establishment situated therein, or performs in that other State independent personal services
   from a fixed base situated therein, and the right or property in respect of which the income is
   paid is effectively connected with such permanent establishment or fixed base. In such case the
   provisions of Article 7 or Article 14, as the case may be, shall apply.
3. Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a
   Contracting State not dealt with in the foregoing articles of this Agreement and arising in the
   other Contracting State may also be taxed in that other State.

1. The laws in force in either of the Contracting States will continue to govern the taxation of
   income in the respective Contracting States except where provisions to the contrary are made
   in this Agreement.
2. In the case of the State of Qatar, double taxation shall be eliminated as follows: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.
3. In the case of India, double taxation shall be eliminated as follows:
   1. 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.
   2. 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.
4. The tax payable in the Contracting State mentioned in paragraphs 2 and 3 of this Article
   shall be deemed to include the tax which would have been payable but for the tax incentives
   granted under the laws of the Contracting State and which are designed to promote economic
   development.

1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any
   taxation or any requirement connected therewith, which is other or more burdensome than the
   taxation and connected requirements to which nationals of that other State in the same
   circumstances, in particular with respect to residence, are or may be subjected. This provision
   shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents
   of one or both of the Contracting States.
2. The taxation on a permanent establishment which an enterprise of a Contracting State has in
   the other Contracting State shall not be less favourably levied in that other State than the
   taxation levied on enterprises of that other State carrying on the same activities. This provision

shall not be construed as preventing a Contracting State from charging the profits of a
permanent establishment which a company of the other Contracting State has in the firstmentioned State at a rate of tax which is higher than that imposed on the profits of a similar
company of the first-mentioned Contracting State, nor as being in conflict with the provisions
of paragraph 3 of Article 7 of this Agreement.

3. Nothing in this Article shall be construed as obliging a Contracting State to grant to residents
   of the other Contracting State any personal allowances, reliefs and reductions for taxation
   purposes on account of civil status or family responsibilities which it grants to its own residents.
4. Nothing in this Article shall be construed as imposing a legal obligation on a Contracting
   State to extend to the residents of the other Contracting State the benefit of any treatment
   preference or privilege which may be accorded to any other State or its residents through
   agreements to which the first-mentioned Contracting State may be a party.
5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or
   controlled, directly or indirectly by one or more residents of the other Contracting State, shall
   not be subjected in the first-mentioned State to any taxation or any requirement connected
   therewith which is other or more burdensome than the taxation and connected requirements to
   which other similar enterprises of the first-mentioned State are or may be subjected.
6. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or
   paragraph 6 of Article 12 apply, interest, royalties and other disbursements paid by an
   enterprise of a Contracting State to a resident of the other Contracting State shall, for the
   purpose of determining the taxable profits of such enterprise, be deductible under the same
   conditions as if they had been paid to a resident of the first-mentioned State.
7. The non-taxation of the share of Qatari nationals in profits of corporate bodies under Qatar’s
   tax law shall not be regarded as discrimination under this Article.
8. In this Article, the term taxation means taxes which are the subject of this Agreement.

1. Where a person considers that the actions of one or both of the Contracting States result or
   will result for him in taxation not in accordance with the provisions of this Agreement, he may,
   irrespective of the remedies provided by the domestic law of those States, present his case to
   the competent authority of the Contracting State of which he is a resident or, if his case comes
   under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The

case must be presented within three years from the first notification of the action resulting in
taxation not in accordance with the provisions of the Agreement.

2. The competent authority shall endeavour, if the objection appears to it to be justified and if
   it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement
   with the competent authority of the other Contracting State, with a view to the avoidance of
   taxation which is not in accordance with the Agreement. Any agreement reached shall be
   implemented notwithstanding any time limits in the domestic law of the Contracting States.
3. The competent authorities of the Contracting States shall endeavour to resolve by mutual
   agreement any difficulties or doubts arising as to the interpretation or application of the
   Agreement. They may also consult together for the elimination of double taxation in cases not
   provided for in the Agreement.
4. The competent authorities of the Contracting States may communicate with each other
   directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.
   When it seems advisable in order to reach agreement to have an oral exchange of opinions,
   such exchange may take place through a Commission consisting of representatives of the
   competent authorities of the Contracting States.

1. 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 exchange of information is not
   restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a Contracting State shall be treated as secret
   in the same manner as information obtained under the domestic laws of that State and shall be
   disclosed only to persons or authorities (including courts and administrative bodies) involved
   in the assessment or collection of, the enforcement or prosecution in respect of, or the
   determination of appeals in relation to the taxes referred to in paragraph 1. Such persons or
   authorities shall use the information only for such purposes. They may disclose the information
   in public court proceedings or in judicial decisions. The information may not be disclosed to
   any other person or entity or authority or any other jurisdiction without the express written
   consent of the competent authority of the requested State.

3. In no case shall the provisions of paragraph 1 and 2 be construed so as to impose on a
   Contracting State the obligation:
   1. to carry out administrative measures at variance with the laws and administrative practice
      of that or of the other Contracting State;
   2. to supply information or documents which is not obtainable under the laws or in the
      normal course of the administration of that or of the other Contracting State;
   3. to supply information which would disclose any trade, business, industrial, commercial or
      professional secret or trade process, or information, the disclosure of which would be
      contrary to public policy(ordre public).
4. If information is requested by a Contracting State in accordance with this Article, the other
   Contracting State shall use its information gathering measures to obtain the requested
   information, even though that other State may not need such information for its own tax
   purposes. The obligation contained in the preceding sentence is subject to the limitations of
   paragraph 3 but in no case shall such limitations be construed to permit a Contracting State to
   decline to supply information solely because it has no domestic interest in such information.
5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting state to
   decline to supply information solely because the information is held by a bank, other financial
   institution, nominee or person acting in an agency or a fiduciary capacity or because it relates
   to ownership interests in a person.

1. The Contracting States 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.
2. Request for assistance by the competent authority of a Contracting State in the collection of
   a revenue claim shall include a certification by such authority that, under the laws of that State,
   the revenue claim has been finally determined. For the purposes of this Article, a revenue claim
   is finally determined when a Contracting State has the right under its internal law to collect the
   revenue claim and the taxpayer has no further rights to restrain collection.
3. Amounts collected by the competent authority of a Contracting State pursuant to this Article
   shall be forwarded to the competent authority of the other Contracting State. However, the firstmentioned Contracting State shall be entitled to reimbursement of costs, if any, incurred in the
   course of rendering such assistance to the extent mutually agreed between the competent
   authorities of the two States.

4. Nothing in this Article shall be construed as imposing on either Contracting State the
   obligation to carry out administrative measures of a different nature from those used in the
   collection of its own taxes or those which would be contrary to its public policy.

Notwithstanding the other provisions of this Agreement, a benefit under this Agreement shall
not be granted in respect of an item of income if it is reasonable to conclude, having regard to
all relevant facts and circumstances, that obtaining that benefit was one of the principal
purposes of any arrangement or transaction that resulted directly or indirectly in that benefit,
unless it is established that granting that benefit in these circumstances would be in accordance
with the object and purpose of the relevant provisions of this Agreement.

Nothing in this Agreement shall affect the fiscal privileges of diplomatic agents or consular
officers under the general rules of international law or under the provisions of special
agreements.

1. The Contracting States shall notify each other in writing, through diplomatic channels, the
   completion of the procedures required by the respective laws for the entry into force of this
   Agreement.
2. This Agreement shall enter into force on the date of the receipt of the later of the notifications
   referred to in paragraph 1 of this Article.
3. The provisions of this Agreement shall have effect in India and Qatar in respect of income
   arising on or after the first day of the fiscal year immediately following the calendar year in
   which the Agreement enters into force.
4. The provisions of the Agreement between the Government of the Republic of India and the
   Government of the State of Qatar for the Avoidance of Double Taxation and the Prevention
   of Fiscal Evasion with respect to Taxes on Income signed at New Delhi on the 7th day of
   April, 1999 shall cease to have effect on provisions of this Agreement becoming operative as
   per paragraphs 2 and 3 of this Article.

This Agreement shall remain in force indefinitely until terminated by a Contracting State.
Either Contracting State may terminate this Agreement, through diplomatic channels, by giving
notice of termination at least six months before the end of any calendar year beginning after
the expiration of five years from the date of entry into force of the Agreement. In such event,
the Agreement shall cease to have effect in India and Qatar, in respect of income arising on or
after the first day of the fiscal year immediately following the calendar year in which the notice
of termination is given.

In witness whereof the undersigned, being duly authorized thereto, have signed this Agreement.

DONE in duplicate at New Delhi this 18th day of February 2025, each in the Arabic, Hindi and
English languages, all texts being equally authentic. In case of divergence of interpretation, the
English text shall prevail.

At the signing of the Agreement between the Government of the Republic of India and the
Government of the State of Qatar for the Avoidance of Double Taxation and the Prevention of
Fiscal Evasion with respect to taxes on income, both sides have agreed upon the following
provisions which shall be an integral part of the Agreement:

1. Ad. Article 11

It is clarified that for the purposes of paragraph 3 of Article 11 of the Agreement, the term
“State” shall include:

1. in the case of India, Reserve Bank of India and the Export Import Bank of India;
2. in the case of Qatar, the Qatar Investment Authority and Qatar Holding LLC;

In witness whereof the undersigned, being duly authorized thereto, have signed this protocol.

DONE in duplicate at New Delhi this 18th day of February 2025, each in the Arabic, Hindi,
and English languages, all texts being equally authentic. In case of divergence of interpretation,
the English text shall prevail.