The three account types are not taxed alike, and the answer turns on which category your deposit is validly held in rather than on which bank holds it. Where the interest is taxable in India, the bank deducts at source when it credits it. Where it is not, the treatment rests on the account being properly held as a non-resident account, which is why a change in your residency status matters so much. An account that should have been redesignated and was not can be credited on one footing while your return has to be filed on another. Check the category before assuming the treatment.
NRE, NRO and FCNR accounts — what does India require?
- 15+Years of the founder's cross-border experience
- 18,000+Clients served across our offices in India, the USA, Canada and the UAE
- 5.0Google rating
- 4Global offices — India, USA, Canada & UAE
Interest treatment and repatriability differ by account type, and deposits are subject to deduction at source where the interest is taxable. India collects at source before considering any exemption, so most Indian files are a reconciliation and a recovery rather than a payment.
What India requires
Interest treatment and repatriability differ by account type, and deposits are subject to deduction at source where the interest is taxable. Redesignating an account on a change of residency status is a compliance step, not an administrative one.

When the rule breaks
The three NRI account types are not variations on a savings account. They differ in currency risk, in whether interest is taxable in India, and in how freely money can leave.
Where to go from here
The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on NRE, NRO and FCNR accounts — how each is taxed. Ask before the move rather than after it, because most of the useful options expire on the date.
Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.
What these engagements turn on
Indian rent credited to the wrong account for years
A landlord abroad had her tenants paying rent into the account she used for transfers of her overseas salary. Indian receipts and foreign-earned funds had been mixed for years, so the history of the balance no longer matched the category it sat in, and both the treatment of the interest and the route out of India were arguable. We separated the two streams going forward, documented which credits were Indian-source, and filed on that basis. The engagement produced a clean account structure and a reported position the bank statements actually support.
Read how this one runsAccounts redesignated at the point of return to India
A client was moving back to India after many years abroad and asked what to do with a set of non-resident accounts and deposits. Redesignation is a compliance step, and doing it late leaves interest credited on a footing the return cannot support. We listed every account and deposit, set out what each becomes on the change of status and when the change bites, wrote to the banks, and kept the confirmations. The engagement produced a dated redesignation record for each account, ready to sit behind the first resident return.
Read how this one runsDeposits sorted by purpose across the three account types
A family had accumulated balances in India with no logic to where anything sat: money earned abroad, rent, a maturing deposit and a share of a sale, all in whichever account had been opened first. We took each pot in turn and asked three questions of it. What currency risk should it carry, is the interest on it taxable in India, and does it need to be able to leave the country. The engagement produced an account map matching each source of funds to the category that suits its purpose, and instructions the banks could act on.
Read how this one runsInterest credited with no deduction after the holder became resident
A client had returned to India and left his accounts untouched. Interest continued to be credited as though he were still non-resident, with no deduction applied where his new status meant there should have been one. We redesignated the accounts first, because the corrected accounts are what the filings depend on, then went back over the years already reported and filed to put the interest on the right footing. The engagement produced corrected accounts, returns for the intervening years, and a settled position instead of a growing one.
Read how this one runsJoint account held with a parent living in India
A client abroad held an account jointly with her mother in India, used for household expenses. The category the account sat in did not match the way it was being operated, which put both the treatment of the interest and the mother's access in question. We established whose funds they were, which holder's status governs the account, and what mandate the mother needed in order to keep using it. The engagement produced an account in the right category with a documented mandate, and a note of whose income the interest is for reporting.
Read how this one runsForeign-currency deposit maturing into a rupee account
A deposit held in foreign currency was maturing, and the client's instinct was to roll it into whichever account paid the highest rate. Doing so would have changed three things at once: the currency the balance is exposed to, whether the interest it pays is taxable in India, and how freely the money could later leave. We set the alternatives against those three, took instructions, and documented the destination account before the maturity date. The engagement produced a maturity handled on a decision rather than on a default.
Read how this one runsAn NRI Selling Indian Property With Tax Withheld on the Price
Withholding on a sale by a non-resident is applied to the sale value rather than to the gain, so it routinely exceeds the tax due. A lower-deduction certificate obtained before completion avoids locking the difference up until a return is assessed.
Read how this one runsInheriting Property in India While Living Abroad
India does not tax the inheritance itself, but the later sale and the money leaving the country both have positions of their own. The file establishes the cost base to use on that sale and what the remittance will require.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.
Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
What people ask us about NRE, NRO and FCNR accounts — how each is taxed
Three things, and the interest rate is only one of them. They differ in currency: one holds foreign currency, so the balance does not move with the rupee, and the others hold rupees, so it does. They differ in whether the interest they pay is taxable in India, and therefore in whether the bank deducts at source when it credits it. And they differ in how freely the balance can leave the country. Choosing between them is a decision about currency risk, tax treatment and repatriability at once, and the right answer depends on where the money came from and what it is for.
Because that interest is taxable in India, and where interest is taxable the bank deducts when it credits it. The bank is not exercising judgement about your position as a whole: it applies the rate the account and your status require and deposits the amount against your tax identifier. The non-resident rate is generally higher than the tax the same income bears once your actual liability is computed, so the deduction is something to reconcile rather than a final tax. That reconciliation is done by filing an Indian return, and it is an annual exercise rather than a one-off.
Rent arising in India is Indian income and belongs in the account category Indian-source receipts are meant to sit in, not in an account funded from your earnings abroad. Mixing the two is the most common account error we see, and it is hard to unpick later. Once Indian receipts have been credited to an account intended for foreign-earned funds, the history of the balance no longer matches the category it sits in, and both the treatment of the interest and the route the money can take out of India become arguable. Keep the two apart from the start.
Yes, and in the other direction too. Redesignating an account on a change of residency status is a compliance step, not an administrative courtesy the bank handles quietly in the background. Non-resident accounts exist because the holder is non-resident; when that stops being true the accounts have to follow, and until they do, interest is credited and reported on a footing your return cannot support. The same applies on the way out: resident accounts do not become non-resident accounts because you have moved. Tell the bank in writing and keep the confirmation with your tax papers.
That is the purpose of holding a deposit in foreign currency. The balance is denominated in the currency it was placed in, so the rupee moving does not change what you get back in that currency. A rupee deposit does the opposite: the interest may look better and the exchange rate carries the risk. But currency is only one of the three variables. The tax treatment of the interest and the freedom with which the balance can leave India differ by account type as well, and a choice made on the exchange rate alone tends to create a problem on one of the others.
Resident but not ordinarily resident — a transitional category in India between non-residence and full residence, reached on the day counts after returning from a period abroad. While it lasts, certain foreign income stays outside the Indian tax base, which makes the timing of a return to India worth planning rather than leaving to chance. It is temporary, and the window is set by the day-count rules. See RNOR status.
With a tax residency certificate issued by the country you are resident in, plus Form 10F giving the details the certificate does not carry, plus a PAN in the payer's records. The certificate has to cover the period of the payment, and the payer needs it before paying, not afterwards. Missing any of the three and the deductor is obliged to withhold at the domestic rate, which turns a rate reduction into a refund claim. See TRC against Form 10F.



