Tax implications for PIO person on becoming a resident in India

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This discussion explores the tax implications for a Person of Indian Origin (PIO) with an OCI card who becomes a tax resident in India. Initially, a PIO might be considered a Resident but Not Ordinarily Resident (RNOR), meaning their global income is not taxed in India. However, once they exceed 182 days of stay and become a full tax resident, their worldwide income becomes taxable in India, though credit for taxes paid abroad can be claimed under Double Taxation Avoidance Agreements (DTAA). The conversation also highlights the need for expert advice, particularly for DTAA matters between India and Singapore.

Sunil Bali

Sunil Bali (Querist)
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01 March 2024 Hello.

Consider the case of a PIO (with OCI Card) who wants to stay in India over a few months and sometimes could cross into resident limits. How would he/she be taxed under DTAA if the said person becomes resident in India.

Can you point to me an expert in DTAA matters (India and Singapore) to assess tax implications for a PIO who becomes resident in India? How is his global income (Singapore) taxed?

CA R SEETHARAMAN

CA R SEETHARAMAN (Expert)
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01 March 2024 His global income will not be taxable in India.
He will be considered as resident but not ordinary resident (RNOR).

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Sunil Bali

Sunil Bali (Querist)
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01 March 2024 Thanks.
I am keen to evaluate the tax implication when he becomes a Resident post RNOR period and starts staying in India for over 182 days, for example.

CA R SEETHARAMAN

CA R SEETHARAMAN (Expert)
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01 March 2024 In such a case his global income is taxable in India less tax paid outside India.

Sunil Bali

Sunil Bali (Querist)
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01 March 2024 Thanks again.
Can you point me to an expert who can do a specific assessment based on actual income in India and Overseas? DTAA expertise in the context of India - Singapore would be very helpful.

CA R SEETHARAMAN

CA R SEETHARAMAN (Expert)
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02 March 2024 https://www.ey.com/en_in/tax/international-tax-planning

Sunil Bali

Sunil Bali (Querist)
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02 March 2024 Thanks Mr. Seetharaman.

CA R SEETHARAMAN

CA R SEETHARAMAN (Expert)
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02 March 2024 You are welcome...
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