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
| Route | Indian tax | What it needs |
|---|---|---|
| Dividend | 10% | Distributable profits; board or shareholder approval |
| Royalty | 10% | A real licence; arm's-length price |
| Service fee | Technical fees: 10%. | Agreement, evidence of services, benchmark |
| Interest | 10% (development-bank loans can be exempt) | Registered ECB loan |
| Buyback | Domestic rules | Company-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.