What is specific to Japanese companies
The India–Japan treaty applies 10% to dividends, interest, royalties and technical fees. Technical fees are taxable in India even without a PE, so intra-group services need careful pricing.
Treaty rates
| Income | Indian tax under the treaty |
|---|---|
| Dividends | 10% |
| Interest | 10% |
| Royalties | 10% |
| Technical service fees | Technical fees: 10%, taxable even without a permanent establishment. |
| Gains on Indian shares | India can tax under its domestic law, with credit in Japan. |
Permanent establishment
Risk comes mainly from a fixed place, dependent agents and installation projects beyond the treaty period, so watch seconded managers who negotiate in India.
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 Japanese rules change often; confirm the current position before acting. Japanese law points should be confirmed with a Japanese adviser.