Section 211 · Special cases
Section 211 of the Income-tax Act, 2025 — Tax on Non-Resident Sportsmen, Sports Associations and Entertainers
By CA Rajat Agrawal
Updated 04 Jul 2026
Chapter XIII
📜 What the law says — Section 211, Income-tax Act 2025
211. (1) Where the total income of an assessee,—
(a) being a sportsman (including an athlete), who is not a citizen of India
and is a non-resident, includes any income received or receivable by way
of—
(i) participation in India in any game [other than a game the winnings
from which are taxable as specified in section 194(1) (Table: Sl. No.
1)] or sport; or
(ii) advertisement; or
(iii) contribution of articles relating to any game or sport in India in
newspapers, magazines or journals; or
(b) being a non-resident sports association or institution, includes any amount
guaranteed to be paid or payable to such association or institution in
relation to any game, other than a game the winnings from which are
taxable as specified in section 194(1) (Table: Sl. No. 1) or sport played
in India; or
(c) being an entertainer, who is not a citizen of India and is a non-resident,
includes any income received or receivable from his performance in
India,
then, the aggregate of income-tax payable by the assessee shall be computed at the
rate specified in the column C applied on the corresponding income specified in
column B:—
TABLE
Sl. Income Rate of Income-
No. tax payable
A B C
1. Income referred to in clause (a) or (b) or (c). 20%
2. Total income as reduced by income referred to in clause Rates in force.
(a) or (b) or (c).
(2) No deduction in respect of any expenditure or allowance shall be allowed under
any provision of this Act in computing the income referred to in sub-section (1).
(3) It shall not be necessary for the assessee to furnish a return of his income under
section 263(1), if—
(a) his total income during the tax year consisted only of income referred
to in sub-section (1); and
(b) the tax deductible at source under the provisions of Chapter XIX-B has
been deducted from such income.
Interpretation.
In plain language
What Section 211 is about
Section 211 of the Income-tax Act, 2025 (effective from 1 April 2026) levies a special, flat rate of income-tax — 20% (plus applicable surcharge and 4% health and education cess) — on certain India-sourced income of non-resident sportsmen, non-resident sports associations or institutions, and non-resident entertainers. It replaces the well-known Section 115BBA of the Income-tax Act, 1961 and carries the same scheme forward in simpler language. The idea is simple: when a foreign cricketer plays an IPL-style match, a foreign football club receives guarantee money for an exhibition game in India, or an international singer performs at a concert in Mumbai, India taxes that income at a clean flat rate, collected almost entirely through tax deducted at source (TDS), so the non-resident usually never has to deal with Indian tax slabs, books of account or return filing.
Who does Section 211 apply to?
- A non-resident sportsman (including an athlete) who is not a citizen of India — e.g., a foreign cricketer, footballer, tennis player or marathoner.
- A non-resident sports association or institution — e.g., a foreign cricket board receiving guarantee money for matches played in India.
- A non-resident entertainer who is not a citizen of India — e.g., an international musician, dancer or theatre artist performing in India.
Important: an Indian citizen who happens to be a non-resident (say, an Indian cricketer settled abroad) is not covered — such a person is taxed under the normal provisions, not at this flat rate.
Which income is covered?
- For a sportsman: (a) income from participation in any game or sport in India (other than winnings from lotteries, gambling, card games etc., which are separately taxed under Section 128 of the 2025 Act); (b) income from advertisements; and (c) income from contributing articles relating to games or sports in India in newspapers, magazines or journals.
- For a sports association/institution: any amount guaranteed to be paid or payable in relation to any game or sport played in India.
- For an entertainer: income from a performance in India.
Key conditions and features
- Flat 20% rate: tax is 20% of the gross specified income, plus surcharge (based on income level) and 4% cess. The rest of the person's income, if any, is taxed under normal provisions.
- No deductions allowed: no expenditure or allowance can be claimed against this income — travel, agent fees, coaching costs, nothing. Tax is on the gross amount.
- TDS at source: the Indian payer must deduct tax under Section 393 of the 2025 Act (successor to Section 194E of the 1961 Act) at 20% (plus surcharge and cess) at the time of credit or payment, whichever is earlier, and report it in the non-resident TDS return (Form 27Q under the 1961 regime).
- No return filing needed if the non-resident's total income consists only of Section 211 income and the correct TDS has been deducted. This is a big compliance relief.
- DTAA can override: under Section 159 of the 2025 Act, if India's tax treaty with the sportsman's home country provides a more beneficial treatment, the treaty prevails — subject to furnishing a Tax Residency Certificate (and Form 41 details where required).
How it interacts with other provisions
Section 211 is a special-rate provision: the specified income is ring-fenced and taxed separately, so basic exemption limits and slab rates do not apply to it. Winnings from betting or gambling-type games fall under Section 128 (30%), not here. Payments to persons outside the section's scope — for example, umpires, referees, match officials or commentators — have been held by courts under the equivalent 1961 provisions (e.g., the Calcutta High Court in the Indcom case) to be outside this regime, so TDS on them falls under the general non-resident withholding provisions instead. Return filing rules live in Section 263 of the 2025 Act.
Practical implications
- For Indian organisers, franchises and sponsors: you are the one on the hook — deduct 20% (plus surcharge/cess) before paying, deposit it on time, and file the TDS return; failure attracts interest, disallowance and penalty exposure.
- For the foreign sportsman/entertainer: tax is final on gross income; negotiate contracts keeping in mind that no expenses are deductible in India, and check the DTAA for possible relief.
- Net-of-tax contracts: if the Indian payer agrees to bear the tax, the payment must be grossed up, increasing the effective cost.
💡 Example
Example 1 — Foreign footballer: Diego, a Brazilian citizen and non-resident, is paid ₹30,00,000 as participation fees for a tournament in India plus ₹10,00,000 for an Indian brand advertisement — total specified income ₹40,00,000. Tax under Section 211 = 20% × ₹40,00,000 = ₹8,00,000, plus 4% cess of ₹32,000 = ₹8,32,000. Even though Diego spent ₹6,00,000 on travel and his agent, no deduction is allowed — tax is on the gross ₹40 lakh. The Indian organiser deducts this tax at source under Section 393 before paying him. Since this is Diego's only Indian income and full TDS was deducted, he does not need to file an Indian income-tax return.
Example 2 — Foreign sports association: An overseas cricket board is guaranteed ₹1,00,00,000 for an exhibition series played in India. Tax = 20% × ₹1 crore = ₹20,00,000, plus applicable surcharge and 4% cess (for instance, with a 10% surcharge for income above ₹1 crore-linked thresholds where applicable, the total can rise to roughly ₹22.88 lakh). The Indian host must withhold this before remitting the guarantee money, and the board can examine the relevant DTAA for any more beneficial treatment.
A short story: Rohan runs an event company in Jaipur and signed a Kenyan long-distance runner for a city marathon at a fee of ₹12,00,000. His accountant reminded him just in time that under Section 211 read with Section 393, he had to deduct ₹2,40,000 (plus cess) before paying her. He grossed up nothing, deducted correctly, deposited the TDS, and filed the quarterly non-resident TDS return. The runner flew home with her net fee and — because TDS covered her full Indian liability — never had to file an Indian tax return. One reminder saved Rohan interest, penalties and an expense disallowance.
| Payee (non-resident) | Income covered under Section 211 | Tax rate | Expense deduction | ITR needed? |
|---|
| Sportsman / athlete (not an Indian citizen) | Participation in games or sports in India; advertisements; articles on games/sports in Indian newspapers, magazines, journals | 20% + surcharge + 4% cess | Not allowed | No, if this is the only income and full TDS deducted |
| Sports association / institution | Amounts guaranteed to be paid or payable for any game or sport played in India | 20% + surcharge + 4% cess | Not allowed | No, if this is the only income and full TDS deducted |
| Entertainer (not an Indian citizen) | Income from any performance in India (concerts, shows, etc.) | 20% + surcharge + 4% cess | Not allowed | No, if this is the only income and full TDS deducted |
| Umpires, referees, commentators, coaches | Not covered by Section 211 (per judicial view under the equivalent 1961 provision) | Normal non-resident withholding provisions apply | As per normal provisions | As per normal provisions |
Related sections
Frequently asked questions
What is the tax rate under Section 211 of the Income-tax Act, 2025?
A flat 20% on the gross specified income, plus applicable surcharge and 4% health and education cess. No expenses or allowances can be deducted from this income.
Does Section 211 apply to Indian cricketers or artists settled abroad?
No. The section applies only to sportsmen and entertainers who are both non-resident and not citizens of India. A non-resident Indian citizen is taxed under the normal provisions instead.
Does a foreign sportsman have to file an income-tax return in India?
Not if his or her total income consists only of income covered by Section 211 and the correct tax has been deducted at source. If there is any other Indian income, a return under Section 263 becomes necessary.
Who deducts the tax, and under which section?
The Indian payer (organiser, franchise, sponsor, etc.) must deduct TDS under Section 393 of the 2025 Act — the successor to Section 194E of the 1961 Act — at 20% plus surcharge and cess, at the time of credit or payment, whichever is earlier.
Can the sportsman claim expenses like travel, agent fees or training costs?
No. Section 211 taxes the gross amount; no deduction for any expenditure or allowance is permitted against this income.
Can a tax treaty (DTAA) reduce the 20% tax?
Yes. Under Section 159 of the 2025 Act, if the DTAA between India and the sportsman's country of residence is more beneficial, the treaty position prevails, subject to furnishing a Tax Residency Certificate and prescribed particulars.
Are umpires, referees, commentators or coaches covered by Section 211?
Generally no. Courts under the equivalent 1961 provision (Section 115BBA) held that match officials are not 'sportsmen', so their payments fall under the general non-resident TDS provisions rather than this flat-rate regime.
C
CA Rajat Agrawal
Chartered Accountant, EaseValue · Reviewed 04 Jul 2026
This explainer is prepared and reviewed by EaseValue's tax team, based on the text of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
Disclaimer: This page explains the law in general terms for education and is not professional advice. The Income-tax Act, 2025 takes effect from 1 April 2026; provisions, thresholds and interpretations may change. Please confirm your specific position with our team before acting.
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