Chartered Accountants◆Practising since 2016

Germany to India · Repatriation

Moving profits from India to Germany

CA Utsav Dogra, Chartered Accountant, ICAI M. No. 542375 · Updated

In brief

Profit can leave India as a dividend (10%), royalty (10%), service fee, interest (10% (development-bank loans can be exempt)) or buyback. A German corporation holding at least 10% exempts 95% of the dividend under Section 8b of the Corporation Tax Act.

What is specific to German companies

A German corporation holding at least 10% exempts 95% of the dividend under Section 8b KStG, so the Indian 10% is largely a final cost.

Routes compared

RouteIndian taxWhat it needs
Dividend10%Distributable profits; board or shareholder approval
Royalty10%A real licence; arm's-length price
Service feeTechnical fees: 10%.Agreement, evidence of services, benchmark
Interest10% (development-bank loans can be exempt)Registered ECB loan
BuybackDomestic rulesCompany-law limits; FEMA pricing

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

Which route is cheapest?

It depends on the parent's home-country position and the substance behind each charge; dividends are simplest, fees and royalties need contracts and transfer pricing support.

General information as at 5 November 2026, not advice for a particular case. Indian and German rules change often; confirm the current position before acting. German law points should be confirmed with a German adviser.

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