Moving back to India from the UK? Learn RNOR eligibility, duration, UK exit rules under the SRT, and how the India-UK DTAA taxes pensions, ISAs & rental income.
If you've spent years building a life in the UK and you're now weighing a move back to India, one acronym is going to matter more than almost anything else in your financial planning: RNOR. Resident but Not Ordinarily Resident status is the tax buffer that keeps your foreign income out of India's tax net for a couple of years while you settle back in — but only if you understand exactly how long it lasts, how it interacts with your UK exit, and what it doesn't cover.
This guide walks through eligibility, duration, the UK side of the equation (which most RNOR articles ignore entirely), how RNOR interacts with the India-UK tax treaty, and what changes under the new Income-tax Act.
RNOR sits in the middle ground between NRI and full resident status. It's set out in Section 6 of the Income-tax Act, 2025, which takes over from Tax Year 2026-27 onward — but if you're still filing for income earned up to FY 2025-26 (AY 2026-27), you're working under Section 6 of the old 1961 Act instead. Worth noting: this is one of the few provisions where the section number hasn't moved at all, even though the 2025 Act renumbers most of the statute.
The practical effect is simple. As an RNOR, your Indian income gets taxed exactly like a resident's. Your foreign income, though, stays outside India's reach — much as it would if you were still an NRI. That's really the whole purpose of the RNOR category: it buys returning NRIs a bit of breathing room before the full weight of resident taxation kicks in.
Applies to | Doesn't apply to |
|---|---|
UK NRIs who were non-resident in India for 9 of the last 10 years | Someone who's already been shuttling between India and the UK for years |
UK returnees present in India for 729 days or less across the preceding 7 years | Anyone with 730+ India days across the last 7 years |
Indian citizens/PIOs deemed resident under Section 6(1A) of the 1961 Act — Section 6(7) under the 2025 Act | Foreign nationals with no Indian citizenship or PIO status |
Anyone who first clears the "Resident" test for the year | Someone under 182 days who remains an NRI — RNOR never applies if you're still an NRI |
One thing that trips people up: a spouse's RNOR clock runs entirely on its own, based on their own day count and residency history. Returning together doesn't mean returning to the same RNOR window.
You only become eligible for RNOR after you've first qualified as a Resident — that means either 182+ days in India during the tax year, or 60+ days in the year combined with 365+ days across the preceding four years. Once you clear that bar, Section 6(6) decides whether you land in RNOR or full ROR territory, using either of two independent tests:
The 9-out-of-10 test — you were non-resident in India in at least 9 of the preceding 10 tax years.
The 729-day test — you spent 729 days or fewer physically in India across the preceding 7 tax years.
You only need to clear one of these, not both. For someone who's been away from India for 7+ years, both tests usually pass without much difficulty, which is why RNOR status is close to automatic in year one for most long-term UK NRIs.
As for how long it lasts: typically two to three financial years. If you've been abroad for a decade or more, you'll generally get the full three years, since the 9-out-of-10 test takes that long to fail. Shorter stints of five or six years often taper to just one or two years of RNOR, because the 9-out-of-10 test fails sooner. There's also a timing trick worth knowing — returning in February or March rather than April can buy you an extra transition year, simply because your first Resident year starts later in the cycle.
Two automatic triggers push someone into RNOR regardless of the tests above. The 120-day rule catches anyone with Indian income over ₹15 lakh who spends 120–181 days in India (with 365+ days in the prior four years) — they become Resident but automatically land in RNOR that year. Separately, Section 6(1A) deemed residency applies to Indian citizens earning more than ₹15 lakh in India who aren't liable to tax anywhere else by reason of domicile or residence; they too are treated as RNOR.
One open question I couldn't fully resolve: whether any Section 6(6) sub-clause lettering has shifted under the 2025 Act beyond what's already confirmed publicly. If this matters to your specific situation, it's worth checking the official 1961-to-2025 section mapping utility closer to your filing date, since CBDT continues to update it.
This is the part almost every RNOR guide skips, and it can end up costing a returning NRI a full extra year of UK tax if handled carelessly. Booking a one-way ticket to India doesn't end your UK tax residency — HMRC applies its own Statutory Residence Test (SRT), and getting your exit date wrong is a genuinely expensive mistake.
There are three "automatic overseas" tests that can make you non-UK-resident from the year you leave:
Fewer than 16 days in the UK during the tax year, if you were UK-resident in any of the previous three years.
Fewer than 46 days in the UK, if you weren't UK-resident in any of the previous three years.
Full-time work overseas — broadly, averaging something close to 35 hours a week — provided you spend fewer than 91 days in the UK and work more than three hours on fewer than 31 of those days.
Here's the catch that trips people up: your actual departure year almost always still counts as a UK-resident year by default, because HMRC assesses residency across the whole tax year. What rescues you is split-year treatment, which carves that single tax year into a UK portion and an overseas portion. It applies automatically once you meet the conditions — you don't elect into it — and there are eight defined cases in total, three of which cover people leaving the UK. Get the wrong case, or fail to meet the following year's non-residence requirement, and HMRC can end up taxing your entire worldwide income for that transition year, not just the part earned while you were still there.
This is where a lot of otherwise good articles blur a distinction that can genuinely cost you money. The India-UK Double Taxation Avoidance Agreement — the 1993 convention, still in force — splits pension income across two separate articles, and which one applies changes everything:
Article 19(2), government pensions: a pension paid by a government for services rendered to that government is taxable only in the paying state. So an NHS or civil-service pension stays taxable only in the UK once you become an Indian resident — there's no nationality carve-out written into this particular treaty.
Article 20, everything else: private and workplace pensions fall here, and so — this is the part people miss — does the UK State Pension. Article 20(2) defines "pension" to include any payment made under the social security legislation of either country, which pulls the State Pension squarely into Article 20. That means it's taxed by residence, not by who pays it.
Once your RNOR window closes and you become a full ROR, both your UK workplace/State Pension and any UK rental income become taxable in India, with a foreign tax credit available (via Form 67) for tax you've already paid in the UK. ISAs lose their tax-free status the moment you're no longer a UK resident for treaty purposes — as an Indian resident, ISA gains and dividends become fully taxable in India. That makes your RNOR window the natural moment to either liquidate an ISA or otherwise reset its cost basis while it's still tax-free. If you're weighing a QROPS transfer, be aware it typically triggers a 25% overseas transfer charge, so in most cases leaving the pension where it is and drawing it down from the UK works out cheaper. And none of this treaty relief is automatic — you'll need a UK Tax Residency Certificate from HMRC and a completed Form 10F before a payer will apply the treaty rate instead of default withholding.
Since 6 April 2025, the UK has moved away from a domicile-based inheritance tax system to a residence-based one, and this is a change that catches a lot of returning NRIs off guard. Anyone who's been UK tax resident for 10 or more of the previous 20 tax years becomes a "long-term resident" (LTR) for IHT purposes, and an LTR's entire worldwide estate — not just UK assets — stays inside the 40% UK IHT net.
The reason this matters for RNOR planning is that leaving the UK doesn't switch this off immediately. An LTR's global estate remains exposed for a "tail" period: a minimum of three years if you were resident for 10–13 of the last 20 years, rising by one year for every additional year of residence, up to a maximum of ten years for someone who was resident for the full 20-year stretch. UK-situated property and shares stay taxable regardless of how long the tail runs. If you've held significant UK assets for a decade or more, this is worth a conversation with a cross-border adviser before you move — RNOR softens your income tax exposure, but it does nothing for this.
Example 1 — the straightforward case. Suresh worked in Manchester for 11 years and returns to Pune on 15 June 2026. He spends 230 days in India that year, comfortably clearing the 182-day Resident test. He was non-resident in India for all 10 of the preceding 10 years, so the 9-out-of-10 test is an easy pass. He's RNOR. His UK workplace pension of £18,000 a year, sitting in his UK account, stays untaxed in India. Only his ₹1,40,000 in Indian FD interest gets taxed: ₹1,40,000 × 30% = ₹42,000, plus 4% cess (₹1,680), for a total of ₹43,680 payable, adjusted against any TDS already deducted.
Example 2 — the closer call. Priya returns to Bangalore from London after just 5 years abroad, having lived in India for a decade before that. She spends 200 days in India, clearing Resident status, but was only non-resident for 5 of the last 10 years — she fails the 9-out-of-10 test. Falling back to the alternate route, her total India presence over the preceding 7 years works out to 640 days, under the 729-day cap, so she still qualifies as RNOR through the second test. Her £4,000 UK ISA gain stays untaxed this year. Had she failed both tests, that same £4,000 (roughly ₹4,24,000 at ₹106/GBP) would have been added straight to her taxable income.
Confirm Resident status first. Count your India days: 182+ in the year, or 60+ in the year combined with 365+ across the prior four years, and you're Resident.
Run the 9-out-of-10 test across the preceding 10 tax years.
Run the 729-day test across the preceding 7 tax years, in parallel with step 2.
Either test passing means RNOR for that year. Keep re-testing annually until both tests fail — at that point you become a full ROR.
Track your UK exit date under the SRT separately, and work out whether split-year treatment applies. This anchors your UK-side reporting and doesn't automatically follow your Indian residency timeline.
You filed as ROR when you actually qualified for RNOR. File a revised return under Section 139(5) of the 1961 Act before the assessment year's deadline, and be ready to recompute your residential status with travel records as supporting evidence.
Your bank kept your NRE account live for months after you'd already become a Resident under FEMA. Notify the bank in writing immediately and ask for redesignation to a resident or RFC account. Interest earned as a Resident is taxable from your actual date of residency change, regardless of how long it takes the bank to update its records — the Income-tax Act operates independently of FEMA on this point.
You claimed DTAA relief on a UK pension without a Tax Residency Certificate or Form 10F. The assessing officer is entitled to deny the treaty rate and apply full domestic TDS instead. Get the TRC from HMRC and file Form 10F before you claim the relief, not after you've already received a notice about it.
Passport with entry/exit stamps, or a detailed travel log (rebuild it from boarding passes and visas if you don't have one)
PAN card — apply now if you don't already have one
UK Tax Residency Certificate from HMRC, needed for any DTAA claim
Form 10F, filed on the e-filing portal or directly with the payer
Bank statements showing NRE/FCNR/RFC balances and interest credited
Employment or pension letters confirming whether your UK income is government or private in origin
Wrongly claiming RNOR when you were actually a full ROR can trigger a Section 270A penalty — up to 50% of the tax on the under-reported income for genuine under-reporting, rising to 200% if it's treated as misreporting (things like false entries or claims not backed by evidence). Filing your ITR late brings the Section 234F fee (₹1,000 if your income is under ₹5 lakh, ₹5,000 otherwise), plus 1% monthly interest under Section 234A. Failing to disclose foreign assets once you're a full ROR risks a flat ₹10 lakh penalty per year under Sections 42–43 of the Black Money Act, 2015.
I wasn't able to confirm the exact corresponding section numbers for 270A and 234F under the 2025 Act at the time of writing — the CBDT mapping utility hadn't published a formal cross-reference for these when this was checked, so it's worth verifying against the current mapping before relying on specific citations in a filing.
No. NRI means you failed the Resident test entirely for that year. RNOR means you passed the Resident test but still qualify for one of two transitional exemptions — it's a category within Resident status, not a substitute for NRI.
You must have been non-resident in India in at least 9 of the 10 tax years immediately before the year you're checking. It's one of two independent paths to RNOR, and you only need to clear one of them.
No. Section 6 keeps its number, and the 9-out-of-10-year and 729-day tests remain identical in substance. Renumbering elsewhere in the Act — like Section 10 moving into a Schedule — doesn't touch the residency provisions.
Typically two to three financial years, depending on how long you were abroad. Ten-plus years abroad usually gets you the full three years; shorter stints taper off faster.
The general one — Article 20, not Article 19. Article 20(2) specifically includes payments made under either country's social security legislation, which covers the State Pension. It's taxed by residence, unlike a genuine civil-service pension under Article 19.
Yes — existing NRE and FCNR deposits run to maturity and stay tax-exempt while you're NRI or RNOR. You just can't open new NRE deposits once you become Resident.
It loses all UK tax-free treatment from India's perspective. Every rupee of ISA gains and dividends becomes taxable in India at slab rate, since the ISA exemption only applies to UK residents.
Notify your bank in writing and request redesignation immediately. There's no fixed FEMA grace period, but the longer you wait, the more audit risk you're carrying. Your tax filing already treats the interest as taxable from your actual residency-change date, regardless of when the bank catches up.
Potentially, yes — if you qualify as a "long-term resident" (10 or more of the last 20 tax years). Your worldwide estate can stay inside UK IHT's reach for anywhere from 3 to 10 years after you leave.
There's no separate application. You self-assess it when filing your ITR, based on your day count and residential history, and keep your travel records ready in case of scrutiny.
Not necessarily. Each of you is tested independently against your own day count and NRI history, so your windows can end up different lengths.
Pull together your UK and India travel records today and run both RNOR tests side by side. If you want to sanity-check the numbers, Toolisky's foreign interest tax calculator can help you see what stays exempt — and it's worth confirming the relevant section numbers against the official 1961-to-2025 mapping utility before you file, since parts of that mapping are still being finalised.
For educational purposes only. Please verify all figures at official sources before acting on them. Toolisky is not affiliated with any government body. Consult a qualified CA or legal professional before making compliance decisions. See toolisky.com/accuracy-and-limitations.
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