What is specific to German companies
Moving a function with profit potential from Germany to India can trigger an exit charge under the German function transfer rules, so document what moves and why.
Moving a function with profit potential from Germany to India can trigger a German exit charge (Funktionsverlagerung).
Our services
How SU and Company helps
We price, document and defend intercompany transactions on the Indian side.
- Functional analysis and benchmarking
- Intercompany agreements review
- Accountant's report and documentation
- Year-end true-ups
- Transfer pricing assessments
Questions
Can transfer pricing disputes be settled in advance?
Yes, through an advance pricing agreement with the Indian tax authorities, bilateral where the treaty partner participates.
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.