The Statutory Brief

IT Act 1961 → 2025 / Section 115A

Non-residents & DTAA

Section 115A → Section 207

Tax on dividends, interest, royalty and FTS of non-residents and foreign companies

Section 115A of the old Income-tax Act, 1961 · new section 207 under the Income-tax Act, 2025

New reference Section 207

Income-tax Act, 1961Section 115A

  • Dividend 20%; IFSC unit dividend 10%
  • Foreign-currency loan interest 20%
  • Royalty/FTS 20% (plus surcharge and cess)

Applies to FY 2025-26 (AY 2026-27) and earlier years.

Income-tax Act, 2025Section 207

  • Rates in a table in section 207
  • Dividend 20%; IFSC dividend 10%; foreign currency interest 20%
  • Royalty and fees for technical services in 207(2)

Applies from tax year 2026-27 (from 1 April 2026).

What changed

Renumbered and tabulated; rates unchanged.

Practice notes

  • Treaty rates often lower; claim under section 159 with TRC.

These are summaries, not the statutory text. Read the bare Act for both sections on the Income Tax Department's official site, which also has a side-by-side comparison utility.

Frequently asked

What is the tax on dividend for NRIs under the new Income Tax Act 2025?

20% under section 207 (10% for dividends from an IFSC unit), subject to lower treaty rates.

What is section 115A called in the new Income-tax Act, 2025?

Section 115A of the Income-tax Act, 1961 corresponds to Section 207 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What changed in section 115A under the new Income Tax Act?

Renumbered and tabulated; rates unchanged.

Is section 115A still applicable for FY 2025-26?

Yes. Income of FY 2025-26 (AY 2026-27) and earlier years is governed by section 115A of the 1961 Act. Section 207 of the 2025 Act applies from tax year 2026-27.

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