What is specific to Australian companies
The India–Australia treaty sets 15% on dividends, interest and royalties (10% for equipment royalties), and treats many technical fees as royalties. Services for more than 183 days in 12 months create a PE.
Treaty rates
| Income | Indian tax under the treaty |
|---|---|
| Dividends | 15% |
| Interest | 15% |
| Royalties | 15% (10% for equipment) |
| Technical service fees | Technical fees are treated with royalties at 15% where they fall within the definition. |
| Gains on Indian shares | India can tax under its domestic law. |
Permanent establishment
Services for more than 183 days in a 12-month period create a permanent establishment.
Our services
How SU and Company helps
We plan and document how money moves back to the parent, at the right treaty rate.
- Dividend, royalty, fee and interest planning
- Treaty withholding and remittance paperwork
- Board and FEMA steps for dividends and buybacks
- Indian figures and certificates for the parent's tax relief
Questions
Does the treaty always beat Indian domestic rates?
The lower of the treaty and domestic rate applies, provided the recipient is the beneficial owner and holds a valid residency certificate.
General information as at 5 November 2026, not advice for a particular case. Indian and Australian rules change often; confirm the current position before acting. Australian law points should be confirmed with a Australian adviser.