What is RNOR status?
RNOR status (Resident but Not Ordinarily Resident) is a middle income-tax category between non-resident and full resident, created by Section 6(6) of the Income-tax Act 1961, in which you are treated as resident in India but your foreign income is still largely exempt from Indian tax. A returning Non-Resident Indian (NRI) almost always passes through RNOR for two to three financial years before becoming an Ordinarily Resident (ROR) whose worldwide income is taxed.
There are three statuses: Non-Resident, RNOR and ROR. RNOR is one stage of the returning to India transition, and it is purely an income-tax concept under Section 6(6). It is separate from your FEMA residency, which governs your bank accounts and flips to resident the moment you return for good. The two routinely coexist: you can already be a resident under FEMA while you are still an RNOR for income tax in the same year.
| Status | What income India taxes |
|---|---|
| Non-Resident (NRI) | India-source income only |
| RNOR | India-source income; most foreign income not taxed |
| ROR | Worldwide income |
What are the conditions to qualify as RNOR? (Section 6(6))
You qualify as RNOR for a financial year if you first count as resident (182+ days in India, or the 60+365-day test) and then meet either limb of Section 6(6): you were a non-resident in 9 of the 10 preceding financial years, or you were in India for 729 days or fewer during the 7 preceding financial years. Meeting just one limb is enough. Both your arrival day and departure day count as full days in India when you tally these totals. Two further routes catch Indian citizens or PIOs whose Indian income exceeds ₹15 lakh, the 120-day and deemed-resident rules, and each lands you in RNOR, not full resident, as covered below.
A long-term NRI clears the 9-of-10 limb automatically in the first year or two back, then relies on the 729-day limb to stay RNOR.
| Test | You are RNOR for the year if | Statute | Who it mainly catches |
|---|---|---|---|
| 9-of-10-years limb | You were a non-resident in 9 of the 10 financial years preceding the relevant FY | Sec 6(6), first limb | Long-term NRIs in their first 1–2 years back |
| 729-day limb | You were in India for 729 days or fewer in the 7 financial years preceding the relevant FY | Sec 6(6), second limb | Returnees in year 2–3 who have failed the 9-of-10 limb |
| High-Indian-income visitor (120-day) | Indian citizen/PIO with Indian income above ₹15 lakh, present 120–181 days in the FY plus 365+ days over the prior 4 FYs | Sec 6(1) Explanation 1(b) (Finance Act 2020) → classified RNOR under Sec 6(6) | Frequent-visitor NRIs with large Indian income |
| Deemed resident | Indian citizen with Indian income above ₹15 lakh and not liable to tax in any other country | Sec 6(1A) → classified RNOR under Sec 6(6) | "Stateless" high-income citizens |
How long does RNOR status last after returning to India?
RNOR status lasts 2 to 3 financial years for most returning NRIs, and your arrival date decides which. Because a returnee becomes resident once they spend 182 days or more in India in a financial year (the 60+365 alternative can also apply, but a long-term NRI rarely has 365 days in India across the prior four years), returning after 1 October keeps you below 182 days and a non-resident for that whole year, adding one extra tax-free year and pushing your two RNOR years into the following years, for three years of foreign-income protection in total. Return before October and you trigger residency immediately, so your RNOR window opens that year and typically runs two years. You become an Ordinarily Resident, and worldwide-taxable, only when both Section 6(6) limbs fail: you have been resident in 2 or more of the last 10 financial years AND have spent 730 days or more in India across the last 7.
Worked example: the arrival-date lever (illustrative; AY 2026-27 onward). Both Ravi and Meera were continuously non-resident from FY 2010-11 to FY 2024-25 (15 years abroad), and both settle in India permanently in 2025. Only their arrival date differs.
| Financial year | Ravi (returns 1 Apr 2025) | Meera (returns 5 Oct 2025) | Foreign income taxable? |
|---|---|---|---|
| FY 2024-25 | NRI (still abroad) | NRI (still abroad) | No, for both |
| FY 2025-26 | RNOR (first resident year) | NRI (below 182 days) | No, for both |
| FY 2026-27 | RNOR (second resident year) | RNOR (first resident year) | No, for both |
| FY 2027-28 | ROR (window closed) | RNOR (second resident year) | Yes for Ravi. No for Meera. |
| FY 2028-29 | ROR | ROR (window closed) | Yes, for both |
Ravi gets two RNOR years and Meera three: by arriving after 1 October she gained a full tax-free non-resident year (FY 2025-26) before her RNOR window even opened. A returnee arriving mid-year before October, say 1 June with roughly 304 days in India, can also reach a third RNOR year on the 729-day limb, because the low first-year day count keeps the prior-7-year total at or below 729 for one more year.
What income is tax-free during the RNOR window?
Foreign income is not taxable in India during RNOR, under the proviso to Section 5(1) of the Income-tax Act 1961: overseas salary, foreign rent, foreign dividends, foreign interest and capital gains on foreign assets sold abroad all stay outside Indian tax while you are RNOR. The single exception is income from a business controlled from India or a profession set up in India, which is taxed even for an RNOR. Interest on FCNR and RFC deposits stays tax-free during this window, while India-sourced income, such as Indian salary, Indian rent, NRO interest (30% TDS) and Indian capital gains, is taxed as it is for any resident.
| Income type | Taxable during RNOR? | Basis |
|---|---|---|
| Indian-source income (Indian salary, Indian rent, NRO interest @30% TDS, Indian dividends/capital gains) | Taxable | Sec 5(1) |
| Foreign income from a business controlled from / profession set up in India | Taxable | Proviso to Sec 5(1) |
| Other foreign income (overseas salary, foreign rent, foreign dividends/interest, foreign capital gains sold abroad) | Not taxable | Proviso to Sec 5(1) |
| FCNR and RFC deposit interest | Exempt | Sec 10(15)(iv)(fa) / Sec 10(4) |
| NRE account interest | Exemption technically lapses once you are resident (including RNOR); convert to RFC to keep it exempt | Sec 10(4)(ii); see accounts section below |
Selling appreciated foreign stocks or ETFs while you are RNOR means the capital gains are not taxed in India, and you can reacquire at market where permitted, so your cost basis is stepped up before global taxation begins. Foreign funds you bring into India during RNOR are not taxed as income either, which makes these the years to consolidate overseas savings at home.
How does RNOR status affect your loans and loan interest?
RNOR status does not change your loan contract, but it changes the maths of whether to keep or prepay it, because your foreign income is still tax-free while your Indian tax outgo is low. Higher tax-free disposable income during RNOR can lift your loan eligibility if you are borrowing, and it gives you cheap headroom to prepay: floating-rate home loans carry zero prepayment penalty for non-business borrowers from 1 January 2026. Because your foreign income escapes Indian tax in these years, the effective cost of servicing an Indian home loan from foreign earnings is at its lowest, which returning NRIs should weigh before deciding to foreclose.
Two cautions apply. EMIs on floating-rate loans can still move with the repo rate regardless of your residency, so weigh whether your EMI or tenure changes when you return before you commit cash to a prepayment. The home-loan interest deduction under Section 24(b) only helps to the extent you have taxable Indian income to set it against, which during RNOR is often modest, so a large prepayment can waste a deduction you cannot fully use.
How do the 120-day and ₹15 lakh rules change RNOR?
The 120-day rule makes an Indian citizen or PIO a resident at 120 days in India (instead of 182) if their Indian income exceeds ₹15 lakh in the year and they were in India 365+ days over the preceding four years, and anyone caught by it is classified as RNOR, not Ordinarily Resident, so foreign income stays exempt. This rule was introduced by the Finance Act 2020 (effective AY 2021-22) and amends the day-count Explanation to Section 6(1). A separate deemed resident rule under Section 6(1A) treats an Indian citizen with Indian income above ₹15 lakh who is not liable to tax in any other country as resident regardless of days, and again lands them in RNOR. Both routes speed up residency for high-Indian-income NRIs, but they are still classified RNOR, so genuine foreign income stays exempt.
The ₹15 lakh threshold is measured on Indian-source income only: foreign income, including NRE and FCNR interest, is left out of it. Because both routes produce RNOR, Schedule FA is not triggered either.
The full mechanics of the 182-day, 60+365 and 120-day residency tests are covered on the residency page. These are the provisions in force for AY 2026-27; check them again after each Budget.
What happens to your NRE/FCNR accounts and DTAA claims as an RNOR?
As an RNOR you cannot keep an ordinary NRE account, because your FEMA status flips to resident the moment you return permanently, even though your income-tax status is still RNOR. Under RBI/FEMA rules you must redesignate NRE and NRO accounts to resident accounts, or move NRE/FCNR funds into a Resident Foreign Currency (RFC) account to keep them in foreign currency. The NRE interest exemption applies only while you are a non-resident, so it lapses once you are RNOR; the clean route is to convert to RFC, whose interest stays exempt under Section 10(15)(iv)(fa). You can still use India's DTAAs to avoid double tax on any doubly-taxed income by filing the prescribed foreign tax credit form (Form 67 under the 1961-Act rules), and because an RNOR is a resident, the Section 87A rebate is available to you.
FEMA decides which account you may hold; income tax decides what is taxed. On return, work through three account actions:
- Redesignate your NRO account to a resident account.
- Convert your NRE account, and any FCNR balances not locked in a running term deposit, to a resident account or, to stay in foreign currency, an RFC (Resident Foreign Currency) account: moving your NRE and FCNR balances into an RFC account is the usual route, and the conversion mechanics are covered there.
- Let existing FCNR fixed deposits run to maturity, then redesignate them.
Skipping these conversions carries its own cost: see the penalties for not converting your accounts under FEMA.
How do you claim and prove RNOR status when you file?
You claim RNOR status by selecting "Resident but Not Ordinarily Resident" in the residential-status section of ITR-2 (or ITR-3 if you have business income) when you file on the income-tax portal, based on your own day-count under Section 6. The department does not certify it for you. As an RNOR you are generally not required to report foreign assets in Schedule FA or foreign income in Schedule FSI; those obligations start only once you become an Ordinarily Resident. You must still report all India-taxable income correctly. Keep passport stamps, entry/exit records, a day-count working showing which Section 6(6) limb you meet, and statements for every India-source income you report, because the residential-status claim is self-declared and must survive scrutiny.
From the ROR year, worldwide income is taxed, foreign assets must be reported in Schedule FA, foreign tax credit is claimed on the prescribed form (Form 67 under the 1961-Act rules), and the Black Money (Undisclosed Foreign Income and Assets) Act 2015, with its flat 30% tax and penalty of up to 90% on undisclosed foreign assets, starts to apply.
Frequently asked questions
How long can I keep RNOR status after returning to India?
RNOR status usually lasts 2 to 3 financial years after you return to India, and your arrival date decides which. Returning after 1 October keeps you below 182 days and non-resident for that year, adding an extra tax-free year and giving you three years of protection. You stay RNOR while you were non-resident in 9 of the last 10 financial years, or in India 729 days or fewer over the last 7.
Is foreign income taxable during the RNOR period?
Foreign income is not taxable in India during the RNOR period under the proviso to Section 5(1) of the Income-tax Act 1961. Overseas salary, foreign rent, foreign dividends, foreign interest and capital gains on foreign assets sold abroad stay outside Indian tax. The only exception is income from a business controlled from India or a profession set up in India, which remains taxable even for an RNOR.
Can an RNOR keep an NRE account, and is the interest still tax-free?
An RNOR cannot keep an ordinary NRE account, because your FEMA status becomes resident the moment you return permanently. You must redesignate NRE and NRO accounts to resident accounts, or move NRE and FCNR funds into a Resident Foreign Currency (RFC) account. The NRE interest exemption applies only while you are non-resident, so the clean route to keep interest tax-free during RNOR is to convert to an RFC account.
What are the two tests to qualify as RNOR?
You qualify as RNOR under Section 6(6) of the Income-tax Act 1961 if you meet either of two tests, after first counting as a resident. First, you were a non-resident in 9 of the 10 financial years preceding the relevant year. Second, you were in India for 729 days or fewer across the 7 preceding financial years. Meeting just one test is enough.
Does an RNOR have to disclose foreign income or file Schedule FA?
An RNOR generally does not have to disclose foreign income or foreign assets, and is not required to fill Schedule FA or Schedule FSI in the ITR. Those obligations begin only when you become an Ordinarily Resident. An RNOR files ITR-2 (or ITR-3 with business income), reports all India-source income, and can claim DTAA relief on the prescribed foreign tax credit form (Form 67 under the 1961-Act rules) where income is taxed in two countries.
When does RNOR status end and global income become taxable?
RNOR status ends and you become an Ordinarily Resident once both Section 6(6) tests fail: that is, you have been resident in 2 or more of the last 10 financial years and have spent 730 days or more in India across the last 7. This usually happens in the third or fourth year of full presence. From that year your worldwide income is fully taxable, foreign assets must be disclosed in Schedule FA, and the Black Money Act applies.