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HMRC internal manual

Double Taxation Relief Manual

India: Royalties and fees for technical services

Royalties and fees for technical services arising in India and paid to a resident of the United Kingdom may be taxed in both countries. The Indian tax chargeable is limited to:

15 per cent where the payer of the fees or royalties is the Indian government or a political sub-division,

10 per cent where the payment is made for the use of, or the right to use, industrial, commercial or scientific equipment or for technical fees payable in connection with the use of equipment, and

15 per cent in other cases (during the first five years after the agreement had effect the rate in other cases was 20 per cent.)

See INTM163090 & 168062 for details of the calculation of tax credit relief.