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ITA 1961 → ITA 2025Special Tax Rates

Section 115A Section 110

Tax on dividends, royalty and technical service fees in the case of foreign companies

RetainedHigh - Reduces compliance burden for foreign investors and licensors.

Quick Answer

Section 115A of the Income Tax Act, 1961 (Tax on dividends, royalty and technical service fees in the case of foreign companies) corresponds to Section 110 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.

What changed for Section 115A

Section 115A of the 1961 Act sets out the rules on tax on dividends, royalty and technical service fees in the case of foreign companies. Prescribes special concessional tax rates (usually 10% or 20%) for foreign companies earning royalties, FTS, or dividends from India.

Under the Income-tax Act, 2025 (effective 1st April 2026), Section 115A is retained and renumbered as Section 110 of the Income-tax Act, 2025. Retained. Ensures India remains competitive for technology transfers and foreign capital.

The transition impact on Section 115A is assessed as High. Reduces compliance burden for foreign investors and licensors.

Old Law (ITA 1961)Ch: XII

Sec 115A

Provision Summary

Prescribes special concessional tax rates (usually 10% or 20%) for foreign companies earning royalties, FTS, or dividends from India.

New Law (ITA 2025)Ch: XI

Sec 110

Provision Summary

Retained. Ensures India remains competitive for technology transfers and foreign capital.

Key Changes & Highlights

  • Exemption from filing ITR granted to non-residents if their only income is under this section and proper TDS has been deducted.

Related Sections

Frequently Asked Questions

Which subject does Section 115A of the 1961 Act cover?

Section 115A of the Income Tax Act, 1961 covers tax on dividends, royalty and technical service fees in the case of foreign companies. Prescribes special concessional tax rates (usually 10% or 20%) for foreign companies earning royalties, FTS, or dividends from India.

What is the new section number for Section 115A under the Income-tax Act, 2025?

Section 115A of the Income Tax Act, 1961 maps to Section 110 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Ensures India remains competitive for technology transfers and foreign capital.

How does the Income-tax Act, 2025 affect Section 115A in practice?

The transition impact for Section 115A is rated High. Reduces compliance burden for foreign investors and licensors.

What is new about Section 115A under the Income-tax Act, 2025?

Exemption from filing ITR granted to non-residents if their only income is under this section and proper TDS has been deducted. These points are specific to Section 115A (Tax on dividends, royalty and technical service fees in the case of foreign companies).

Disclaimer: This mapping of Section 115A (Tax on dividends, royalty and technical service fees in the case of foreign companies) to Section 110 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 115A is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.

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