Understanding Section 10(8A)
Section 10(8A) provides full tax exemption on remuneration received by:
- Non-Indian citizens
working for specified international organizationsin India.
Key Features
✔ Who Can Claim?:
- Foreign nationals (non-Indian citizens)
- Employees/consultants of approved international bodies
✔ Covered Organizations:
- United Nations (UN) & its specialized agencies (WHO, UNICEF, etc.)
- World Bank, IMF, ADB
- Other organizations notified by Central Government
✔ Exempt Income:
- Salaries
- Allowances
- Perquisites
- Any compensation from the organization
✔ Condition: Must be non-Indian citizen
Practical Example
Scenario
Mr. Pierre Dubois (French national), a WHO epidemiologist posted in Delhi:
- Position: Public Health Advisor
- Duration: 2023-2025
- Compensation:
- Base salary: $10,000/month (paid by WHO)
- Housing allowance: ₹1,50,000/month
- Education allowance: ₹75,000/month
Tax Treatment
- All payments($ salary + ₹ allowances) → 100% tax exempt under Sec 10(8A)
- Reason: WHO is a specified international organization + Mr. Dubois is foreign national
- Result: Zero Indian income tax on WHO earnings
Comparison with Similar Sections
| ASPECT | SECTION 10(8A) | SECTION 10(8) | SECTION 10(6) |
| Beneficiary | Foreign nationals only | Any nationality | Diplomats |
| Employer | Specified int’l orgs | Govt-approved programs | Foreign governments |
| Citizenship | Non-Indian required | No restriction | Non-Indian required |
