What is specific to German companies
The India–Germany treaty, in force since 26 October 1996, applies a flat 10% to dividends, interest, royalties and technical fees, among the simplest rate structures India has.
Treaty rates
| Income | Indian tax under the treaty |
|---|---|
| Dividends | 10% |
| Interest | 10% (development-bank loans can be exempt) |
| Royalties | 10% |
| Technical service fees | Technical fees: 10%. |
| Gains on Indian shares | India can tax under its domestic law; Germany exempts 95% of a corporate seller's gain. |
Permanent establishment
Fixed place, dependent agents and construction or assembly projects beyond the treaty period.
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 German rules change often; confirm the current position before acting. German law points should be confirmed with a German adviser.