Tax on Non-Resident Sportsmen and Sports Associations: Section 211 of the Income Tax Act 2025

Section 211 of the Income Tax Act 2025 taxes income earned in India by a non-resident foreign sportsman, a non-resident foreign entertainer, or a non-resident sports association at a flat 20%. No expense can be deducted from that income. The payer deducts the same 20% at source under section 393(2), Table Sl. No. 1, and if that tax was deducted the payee need not file a return.

This guide explains who is covered, which income is covered, how the 20% works alongside the rest of the person's income, and what the payer must do. Every figure comes from the Act as amended by the Finance Act 2026 (tax year 2026-27), with the section number beside it. Last reviewed on 10 November 2026. This is general information, not tax advice.

Who does section 211 apply to?

Section 211(1) applies to three kinds of assessee. In each case the person must be a non-resident.

Assessee (section 211(1))	Extra condition	Income covered
Sportsman, including an athlete (clause (a))	Not a citizen of India	Income from playing in India, advertisement, and writing about games or sports in Indian newspapers, magazines or journals
Sports association or institution (clause (b))	Non-resident	Any amount guaranteed to be paid or payable in relation to a game or sport played in India
Entertainer (clause (c))	Not a citizen of India	Income received or receivable from performance in India

The citizenship condition matters. A non-resident sportsman who is an Indian citizen is not within clause (a) and is taxed under the ordinary provisions.

Which income is taxed at 20%?

For a sportsman, section 211(1)(a) lists three streams:

• Participation in India in any game or sport. Winnings from games taxed under section 194(1), Table Sl. No. 1 (lottery, crossword puzzle, races, card games, gambling and betting) are carved out and taxed there at 30%.
• Advertisement. The text does not say the advertising must be done in India, so read the clause as written and check the facts of the contract.
• Contribution of articles relating to any game or sport in India in newspapers, magazines or journals.

For a sports association or institution, clause (b) covers any amount guaranteed to be paid or payable for a game or sport played in India, again excluding the section 194(1) Sl. No. 1 games. For an entertainer, clause (c) covers income from the performance in India.

How is the tax computed?

Section 211(1) splits the assessee's income in two and taxes each part separately. The tax is the total of both rows.

Sl. No.	Income	Rate
1	Income referred to in clause (a), (b) or (c)	20%
2	Total income reduced by that income	Rates in force

Section 211(2) adds a harsh rule: no deduction for any expenditure or allowance is allowed under any provision of the Act when computing the section 211(1) income. The 20% is charged on the gross amount.

This note does not work out surcharge or cess, because the files used for this article do not address them. Check the current Finance Act position before quoting a final cost to a client.

Worked example 1: a foreign athlete in an Indian league (tax year 2026-27)

Assumptions: Daniel is a non-resident foreign athlete and not an Indian citizen. In the tax year he earns Rs 50,00,000 for playing in a league in India and Rs 10,00,000 from an advertisement contract. He claims Rs 12,00,000 of travel, coaching and agent costs. He has no other Indian income.

Step	Working	Rs
1. Section 211(1)(a) income	50,00,000 + 10,00,000	60,00,000
2. Deduction for the Rs 12,00,000 costs	Not allowed (section 211(2))	0
3. Tax at 20% (Sl. No. 1)	60,00,000 x 20%	12,00,000
4. Rest of total income	60,00,000 - 60,00,000	0
5. Tax at rates in force (Sl. No. 2)	On nil	0
Tax (before any surcharge or cess)		12,00,000

Worked example 2: a foreign sports association with a guarantee (tax year 2026-27)

Assumptions: a non-resident sports association is guaranteed Rs 2,00,00,000 for sending its team to play a series in India. It spends Rs 30,00,000 on the tour and has no other Indian income.

Step	Working	Rs
1. Guaranteed amount, clause (b)	As stated	2,00,00,000
2. Tour expenses	Not allowed (section 211(2))	0
3. Tax at 20%	2,00,00,000 x 20%	40,00,000

If expenses were allowed, a 20% charge on Rs 1,70,00,000 would give Rs 34,00,000. Section 211(2) makes the difference of Rs 6,00,000 a real cost.

Does the payer have to deduct TDS?

Yes. Section 393(2), Table Sl. No. 1 covers any income referred to in section 211. The payee is a non-resident sportsman (including an athlete) or entertainer who is not an Indian citizen, or a non-resident sports association or institution. The payer is any person, and the rate is 20%.

Under section 393(2)(b), tax is deducted at the time the income is credited to the payee's account or paid, whichever is earlier. Rule 218(2) sets the deposit date for such deductors: by 7 days from the end of the month of deduction, or 30 April where the credit or payment is in March. The statement of deduction is covered by rule 219, which lists Form 144 against section 393(2) payments to a non-resident who is not a company or foreign company.

What if the organiser agrees to bear the tax?

Foreign players often negotiate a net fee. Section 393(10) covers this: where the tax on the recipient's income is to be borne by the payer under an agreement or arrangement, the income is grossed up for deduction. The amount is increased until, after deducting tax as per Chapter XIX-B, it equals the net amount payable. For example, at 20%, a net fee of Rs 8,00,000 is grossed up to Rs 10,00,000 and Rs 2,00,000 is deducted.

Can a tax treaty reduce the 20%?

Section 159(4) says that where a notified agreement for relief or avoidance of double taxation applies to the assessee, the Act applies only to the extent it is more beneficial to that assessee. So a treaty with the player's country may help at assessment. Do not assume it lowers the deduction rate, though: the lower-treaty-rate rule in Note 2 to section 393(2) is written for Sl. Nos. 10 and 15 only, not for Sl. No. 1. Check the treaty article and the payee's documents before deducting less than 20%.

Does a non-resident sportsman have to file an income tax return?

Not always. Under section 211(3), the assessee need not furnish a return under section 263(1) if both conditions hold:

• total income during the tax year consisted only of income referred to in section 211(1); and
• tax deductible at source under Chapter XIX-B was actually deducted from that income.

If the person has other income, or the payer did not deduct, this relief does not apply and the normal filing position under section 263 needs to be checked.

Real-life examples

Meena, a tournament organiser in Pune. She invites a foreign tennis player, who is not an Indian citizen and is a non-resident, and agrees a fee of Rs 25,00,000. When she pays or credits it, she deducts 20%, which is Rs 5,00,000, and pays the player Rs 20,00,000. She deposits the Rs 5,00,000 and reports it in her statement of deduction. If the player has no other Indian income, he does not have to file a return.

Ravi, a magazine editor in Delhi. A visiting foreign cricketer who is a non-resident writes a weekly column on the tournament in Ravi's magazine and is paid Rs 3,00,000 in total. Contribution of articles about a game or sport in India to a magazine is listed in section 211(1)(a)(iii), so Ravi deducts 20%, which is Rs 60,000. He does not treat it as an ordinary fee.

Common mistakes

• Applying section 211 to an Indian citizen. Clauses (a) and (c) require the person not to be a citizen of India.
• Letting the payee net off expenses. Section 211(2) bars any deduction, so TDS is on the gross figure.
• Mixing up winnings and appearance fees. Winnings from games under section 194(1), Sl. No. 1 are excluded from section 211 and sit under section 194.
• Missing the advertisement and article streams. Only match fees get noticed, but clause (a) also covers advertisement and newspaper, magazine or journal articles.
• Forgetting the no-return relief has two conditions. It needs only section 211 income and tax actually deducted.

Quick reference

Point	Rule	Where
Rate on sports, advertisement, performance income	20%	Section 211(1), Sl. No. 1
Rate on remaining total income	Rates in force	Section 211(1), Sl. No. 2
Expense deduction	Not allowed	Section 211(2)
Return of income	Not needed if only such income and TDS deducted	Section 211(3)
TDS rate	20%	Section 393(2), Sl. No. 1
TDS deposit	7 days from month end; 30 April for March	Rule 218(2)

Where this is in the Act

• Section 211: tax on non-resident sportsmen or sports associations
• Section 194(1), Table Sl. No. 1: winnings carved out of section 211
• Section 263(1): return of income, relieved by section 211(3)
• Section 393(2), Table Sl. No. 1: TDS on payments to a non-resident under section 211
• Rule 218(2): deposit of tax; rule 219: statement of deduction

For a related look at deducting tax on payments, see our guide on TDS on rent under the Income Tax Act 2025. For a CA firm, the hard part is tracking which clients pay non-residents, and when each deposit and statement falls due. Finexo's practice management software keeps those deadlines in one place across your client book. It does not compute TDS or file the forms for you.