Section 10(6A)
Tax paid on behalf of foreign company in respect of royalties or fees for technical services
Quick Answer
Section 10(6A) (Tax paid on behalf of foreign company in respect of royalties or fees for technical services) has been deleted under the Income-tax Act, 2025, effective 1st April 2026.
What changed for Section 10(6A)
Section 10(6A) of the 1961 Act sets out the rules on tax paid on behalf of foreign company in respect of royalties or fees for technical services. Exempted the tax paid by an Indian company on behalf of a foreign company under specific agreements.
The Income-tax Act, 2025 does not retain Section 10(6A): it is deleted with effect from 1st April 2026, so no equivalent section replaces it. NA. Deleted.
On the ground, changes to Section 10(6A) carry a Medium impact. Changed how international royalty contracts are drafted.
Sec 10(6A)
Provision Summary
Exempted the tax paid by an Indian company on behalf of a foreign company under specific agreements.
Deleted
Provision Summary
NA. Deleted.
Key Changes & Highlights
- Grossing up provisions under Section 195A now strictly apply.
Related Sections
Frequently Asked Questions
What does Section 10(6A) of the Income Tax Act 1961 deal with?
Section 10(6A) of the Income Tax Act, 1961 covers tax paid on behalf of foreign company in respect of royalties or fees for technical services. Exempted the tax paid by an Indian company on behalf of a foreign company under specific agreements.
Does Section 10(6A) survive under the Income-tax Act, 2025?
Section 10(6A) has been deleted under the Income-tax Act, 2025, with no successor section carrying it forward from 1st April 2026. NA. Deleted.
Why does the change to Section 10(6A) matter for taxpayers?
The transition impact for Section 10(6A) is rated Medium. Changed how international royalty contracts are drafted.
What are the key changes to Section 10(6A) under the Income-tax Act, 2025?
Grossing up provisions under Section 195A now strictly apply. These points are specific to Section 10(6A) (Tax paid on behalf of foreign company in respect of royalties or fees for technical services).
Disclaimer: This mapping of Section 10(6A) (Tax paid on behalf of foreign company in respect of royalties or fees for technical services) under the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 10(6A) is currently marked Deleted, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
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