What is specific to Chinese companies
The India–China treaty, amended in 2018, applies 10% to dividends, interest, royalties and technical fees; a 183-day test applies to service PEs.
Treaty rates
| Income | Indian tax under the treaty |
|---|---|
| Dividends | 10% |
| Interest | 10% |
| Royalties | 10% |
| Technical service fees | Technical fees: 10%. |
| Gains on Indian shares | India can tax under its domestic law. |
Permanent establishment
Services through employees for more than 183 days 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 Chinese rules change often; confirm the current position before acting. Chinese law points should be confirmed with a Chinese adviser.