India withholding tax rates 2026 and how to repatriate profits

Short answer: India withholds 20% plus surcharge and cess (20.8%–21.84%) on dividends, interest, royalties and technical fees paid to a foreign company in tax year 2026-27; a UK, US, EU, UAE or Singapore parent with a tax residency certificate and Form 41 usually pays the 10%–15% treaty rate instead [1][2][8]. Where the parent's home country exempts dividends, that withholding is a final cost, so arm's-length royalties, service fees and loan interest (deductible in India, taxed at home with credit) often move profits out more cheaply than dividends. Since 1 April 2026 a buy-back from a foreign parent holding over 10% bears 30% of the gain before surcharge and cess, roughly a third all-in, so buy-backs suit returning capital with little built-in gain, not extracting profits [13][14][28][33].

Who this is for: CFOs, heads of tax and general counsel of UK, US, European and UAE groups with cash building up in an Indian subsidiary, or an exit in view. Covers dividends, royalties and fees, loan interest, buy-backs, capital reductions and share sales.

India withholding tax rates 2026: the domestic grid

From 1 April 2026 the Income-tax Act 2025 replaced the 1961 Act: non-resident rates sit in s.207 (formerly s.115A) and the payer withholds under s.393(2) (formerly s.195), whose table keeps the legacy 5% interest entries [4][2][39].

*Surcharge 2% where Indian income exceeds INR 1 crore, 5% above INR 10 crore; cess 4%. Rates apply to the gross payment (no deductions) [4]; treaty rates carry no surcharge or cess [2].

Treaty withholding rates: UK, US, EU, UAE and Mauritius

India applies a more beneficial treaty (s.159(4)) only if the recipient provides a tax residency certificate (TRC) and Form 41, the successor to Form 10F (s.159(8)) [6][8]; see Form 10F (now Form 41) and tax residency certificate.

Sources: [1][2][9][10][11]. France's protocol of 23 February 2026 was not in effect at PwC's last review (11 May 2026) [2].

Every rate requires the parent to be the beneficial owner, not a conduit. The principal purpose test (PPT) has applied to the UK, UAE, Singapore and Dutch treaties since 1 April 2020; the US uses an Article 24 limitation-on-benefits test; one source reports the 2024 India–Mauritius PPT protocol in force from 10 August 2026, adviser notes of July–September 2026 still describe ratification and notification between the two states as incomplete, and no Indian s.159 notification has been located [9][10][25][31][32]. Nestle (Supreme Court, 2023) blocks most-favoured-nation claims without an Indian notification [26]; Tiger Global (Supreme Court, 15 January 2026) makes a TRC necessary but not conclusive [24].

Repatriation of profits from India: the six routes

Dividends and India dividend withholding tax

Dividends come from profit already taxed at 25.168% (s.200 regime) [27], then bear 10% (UK, UAE, Dutch; Singapore ≥25%) or 15% (US). No RBI approval is needed [21]. UK, Dutch, UAE and Singapore parents typically exempt the dividend, so the withholding is a final cost [23]. For a US parent, withholding on a dividend that qualifies for the s.245A deduction is not creditable (s.245A(d)), but withholding on a distribution of earnings already taxed under the US CFC rules can generally be credited, within the limitation [29]; see US–India tax treaty: guide for US companies.

Royalties, technical and management fees

Royalties and fees are deductible in India if priced at arm's length and documented (Form 48). Royalty withholding tax in India is 10%–15% under most treaties, 20% for Italy and Denmark [1]. Under the UK, US, Dutch and Singapore "make available" test, support services that transfer no know-how are not FTS, so India taxes them only through a permanent establishment [9][10] (see Permanent establishment in India (employees, EOR, agents)); the UAE treaty has no FTS article [11]. Continental European treaties lack that carve-out: FTS bear 10% gross (Italy, Denmark 20%) [1]. Expect 18% reverse-charge GST, usually recoverable [21].

Interest on shareholder loans (ECB)

A parent loan is an external commercial borrowing (ECB). Under the Borrowing and Lending Regulations in force since 16 February 2026 the fixed all-in-cost ceiling has gone (pricing must be in line with market conditions), related-party loans must be at arm's length, the minimum average maturity is three years, and a loan registration number (Form ECB 1) is needed before drawdown, with Form ECB 2 filed within seven calendar days after the end of any month in which money is drawn or serviced [17][18][34][35]. Interest to foreign affiliates above INR 1 crore is deductible only up to 30% of EBITDA (s.177) [5]. An Indian subsidiary cannot lend surplus cash to its parent: the overseas-investment rules let it lend only to a foreign entity it has invested in and controls [36].

Buy-backs from 1 April 2026: the promoter tax

From 1 April 2026 buy-back proceeds are capital gains (s.69(1)), not deemed dividends as from October 2024 to March 2026 [13][16][33]. In an unlisted company a holder of over 10%, directly or indirectly, is a "promoter" (s.69(3)), which catches a wholly owning foreign parent [15][28][33]. A promoter that is not a domestic company pays an additional 17.5% on long-term gains (s.69(2)), taking the rate to 30% before surcharge and cess; the Finance Act 2026 (s.3(6)) adds a 12% surcharge on that additional tax and confines it to Companies Act s.68 buy-backs (capped at 25% of paid-up equity a year) [13][14][33]. All-in: about 33.4%–34.0% of the gain, against 13.0%–13.65% for a holder of 10% or less.

So a buy-back beats a 10% treaty dividend of the same cash only while the gain is under about 30% of the price (45% against a 15% dividend), and it consumes share cost that would shelter a later exit. For Dutch parents the point is contested: in Huntsman (Delhi Tribunal, reported June 2026) a 99.98% parent's buy-back was an Article 13(5) reorganisation outside Indian tax; an earlier Mumbai ruling disagreed [12].

Capital reduction

A reduction under Companies Act s.66 needs NCLT confirmation, typically three to six months [22]. The payout is a deemed dividend up to accumulated profits (s.2(40)(d)), at the treaty dividend rate because treaties define dividends to include income taxed like income from shares (UK Art 11(3)) [9][20][38]; only the balance is a capital gain, and Jupiter Capital (Supreme Court, 2025) confirms a resulting loss is recognised [19]. No promoter tax applies, so a reduction suits returning capital once reserves have been paid out.

Exit by share sale

Long-term gains bear 13.0%–13.65% for UK, US and UAE parents, and for Singapore and Mauritius parents on shares acquired from 1 April 2017 [7][9][11]. A Dutch parent selling to a non-Indian buyer is taxed only in the Netherlands, subject to the PPT [10]. Sales to Indian residents must be at or below fair value [42], proceeds are remitted net of tax [30], and the buyer usually withholds on the gain only with a Form 128 certificate [8].

Does a UAE or GIFT City holding company change the answer?

Not on dividends: a UAE parent gets the same 10% as a UK or Dutch one. The gains are elsewhere: interest 12.5% and royalties 10% (UK/US 15%), no FTS article, a participation exemption for 5%+ holdings held 12 months, and 9% UAE tax on royalties normally covered by the Indian credit [11][23]. In Option B below, a UAE licensor cuts group tax from 30.36% to 25.86%. The condition is substance: the UAE company must own and manage the IP or deliver the services with its own people, or the PPT and Tiger Global remove the rate; exit gains are not sheltered. Dividends paid by an IFSC unit in GIFT City bear 10% (s.207(1)) [1][4]. See Invest in India: choosing a holding company jurisdiction (hub).

Decision table: which route to repatriate profits from India

A branch is a different model: profits taxed at 36.4%–38.22% (MAT at 14% may apply) [41], then remitted without further Indian tax — see India corporate tax rate for foreign companies: subsidiary vs branch vs PE.

Worked example: a UK parent repatriating INR 10 crore of profit

Illustrative only; tax year 2026-27; FX INR 127 = GBP 1 (FBIL reference rate, 12 October 2026, rounded) [37]. A UK plc owns 100% of an Indian subsidiary (paid-up equity INR 20 crore) earning pre-tax profit of INR 10 crore (about GBP 790,000).

A — dividend. Corporate tax 10 × 25.168% = 2.517 crore; withholding 7.483 × 10% = 0.748 crore; cash to UK 6.735 crore. Indian tax 3.265 crore, 32.65%, final if the UK exempts (see UK–India double tax treaty: guide for UK companies). US parent at 15%: 1.122 crore, 36.39%. No TRC/Form 41: 20% × 1.02 × 1.04 = 21.216%, 1.588 crore, 41.04%.

B — INR 3 crore arm's-length royalty, balance as dividend. Corporate tax 7 × 25.168% = 1.762 crore; royalty withholding 3 × 15% = 0.45; dividend withholding 5.238 × 10% = 0.524; UK tax on royalty 0.75 less 0.45 credit = 0.30. Total 3.036 crore, 30.36%: INR 0.23 crore (about GBP 18,000) a year less than A. A UAE licensor (10%, no residual UAE tax): 25.86%.

C — returning INR 4.8 crore. Shares costing 4 crore (20% of equity, within s.68) are worth 4.8 crore; reserves exist. Dividend: 4.8 × 10% = 0.480 crore. Buy-back: gain 0.8 × 33.38% (13.00% + 17.5% × 1.12 × 1.04 = 20.38%; Indian income under INR 1 crore) = 0.267 crore, about GBP 16,800 cheaper today, but the 4 crore of cost consumed adds up to 4 × 13.65% = 0.546 crore on a later exit. Capital reduction: all 4.8 crore is a deemed dividend (0.480), with a 4 crore capital loss for later Indian gains; with reserves already paid out, only 0.8 × 13.00% = 0.104 crore.

D — exit. Sale for INR 60 crore, cost 20: 40 × 13.65% = 5.46 crore (about GBP 430,000; USD 569,000 at INR 96; EUR 510,000 at INR 107) [37]. A Dutch parent selling to a non-Indian buyer: nil [10].

Rule: pay profits as dividends, or as royalties and fees where the parent supplies real IP and services; return capital by buy-back only while the gain is small, otherwise by reduction once reserves are distributed.

How to repatriate money from India: the compliance sequence

1. TRC for the tax year and Form 41 online before the first payment (no PAN needed) [8].
2. Board or shareholder resolution; for dividends, distributable profits (Companies Act s.123).
3. Deduct and deposit tax by the 7th of the following month.
4. Form 146 accountant's certificate above INR 5 lakh (unless a s.395 certificate is held), then Form 145 (ex-15CA) before remitting [3].
5. Bank pack: Form A2, Forms 145/146, TRC, Form 41, challan [21].
6. Quarterly Form 144; issue Form 131 [8].
7. Capital routes: fair-value certificate, AD-bank reporting (including Form FC-TRS within 60 days for a share transfer [40][42]), remittance net of tax [30]. Treaty-rate recipients must file an Indian return, because s.207(8) waives it only where tax was withheld at the full s.207 rates, and a return needs a PAN [4][8].

Risks and common mistakes, ranked

1. Buy-backs from a wholly owned subsidiary not modelled against a dividend and the exit.
2. One answer for every parent: US credit rules and continental FTS articles change it.
3. Paying before TRC and Form 41: 20.8%–21.84% withheld; recovery needs a return and PAN.
4. Treaty claims without beneficial ownership or substance (PPT, US LOB, Tiger Global).
5. Unbenchmarked royalties, fees or loans; interest above the s.177 cap; drawing before ECB registration.
6. Old forms: 15CA, 15CB and 10F do not apply to 2026-27 payments.

Checklist for the group tax team

• Map Indian cash: profits, reserves, paid-up capital, intercompany balances.
• Confirm treaty rate, beneficial ownership and home treatment per route.
• TRC, Form 41 and substance file for the year.
• Arm's-length licence, services and loan agreements; s.177 and ECB checked.
• Any buy-back modelled against a dividend and a capital reduction.
• Bank pack ready before payment; Indian return diarised.

How ATB Corporate can help

ATB Corporate advises companies and investors on entering, structuring and operating in India and the UAE: choosing the entry route and holding structure, tax and exchange-control planning, regulatory compliance, and setting up and running the local business. To discuss your plans, contact ATB Corporate.

FAQ

What is the withholding tax rate in India on dividends paid to a foreign company?

India's withholding tax on dividends paid to a foreign company is 20% plus surcharge and cess (20.8%–21.84%) in tax year 2026-27, unless the parent claims its treaty rate with a tax residency certificate (TRC) and Form 41. The treaty rate is 10% for UK, UAE, Dutch and most EU parents and 15% for a US parent holding at least 10% of the voting stock, with no surcharge or cess on top [1][2].

What are the UK–India and US–India tax treaty withholding rates?

The UK–India and US–India tax treaties set the same withholding rates on interest (15%, or 10% for banks) and on royalties and technical fees (15%, or 10% for equipment royalties), but differ on dividends: 10% for a UK parent, and 15% for a US parent holding at least 10% of the voting stock (25% below that) [1][9]. Each rate needs a TRC and Form 41, and the parent must be the beneficial owner.

Is it cheaper to take money out of India as royalties or dividends?

Taking money out of India as royalties is often cheaper than paying dividends for a parent whose home country exempts dividends, because a royalty is deductible in India and the treaty withholding on it is creditable at home, whereas dividend withholding is a final cost. This works only if the parent owns genuine IP and the royalty is priced at arm's length and documented; in the worked example a UK parent saves about INR 0.23 crore a year on INR 10 crore of profit.

How are share buy-backs taxed in India from April 2026 for a foreign parent?

From 1 April 2026 a share buy-back is taxed in India as a capital gain, and a foreign parent holding over 10% of an unlisted company is a "promoter" that pays an additional 17.5% on long-term gains under s.69(2), taking the rate to 30% of the gain before surcharge and cess, roughly a third all-in [13][14][28][33]. A buy-back therefore suits returning capital with little built-in gain rather than extracting profits.

What forms are needed to repatriate profits from India?

To repatriate profits from India in tax year 2026-27, the foreign parent needs a tax residency certificate and Form 41 before the first payment; the Indian company then needs a Form 146 accountant's certificate (above INR 5 lakh, unless a s.395 certificate is held), Form 145 before remitting and Form A2 for the bank, followed by quarterly Form 144 [3][8]. Forms 15CA, 15CB and 10F do not apply to 2026-27 payments.

Can my Indian subsidiary lend money to its foreign parent?

No, an Indian subsidiary cannot lend surplus cash to its foreign parent as routine treasury, because FEMA's overseas-investment rules allow an Indian entity to lend only to a foreign entity it has invested in and controls [36]. Cash therefore goes up to the parent as dividends, royalties or service fees, or as repayments of a parent loan.

Related reading

• Joint venture in India or acquisition: deal structure and shareholder protections (ATB Legal)
• India tax advisory
• FEMA advisory
• India GCC tax structuring
• India–UAE business structuring
• India GIFT City
• Netherlands–India
• The indirect-transfer cases: Vodafone, Cairn and the treaty backstop
• Treaty selection decides the outcome: the Sanofi case

Sources

1. Income Tax Department, "Tax Rates — DTAA v. Income-tax Act" (treaty rate grid with country conditions; 10% for IFSC-unit dividends) (accessed 12 October 2026) — https://www.incometaxindia.gov.in/w/%E2%80%8Btax-rates-dtaa-v.-income-tax-act
2. PwC Worldwide Tax Summaries, India — Withholding taxes (reviewed 11 May 2026; accessed 12 October 2026) — https://taxsummaries.pwc.com/india/corporate/withholding-taxes
3. Income Tax Department, Rule 220, Income-tax Rules 2026 (Forms 145/146/147) — https://www.incometaxindia.gov.in/w/rule-220-1 (2026)
4. Income-tax Act 2025, s.207 (reproductions; s.207(1) dividends 20%, IFSC-unit dividends 10%, foreign-currency interest 20%; s.207(2) royalty/FTS 20%; s.207(5) no deductions; s.207(8) return exemption) (accessed 12 October 2026) — https://eztax.in/income-tax-act-2025/section-207 ; https://www.taxheal.com/?p=118624
5. Income Tax Department, Income-tax Act 2025 s.177 (interest limitation) — https://www.incometaxindia.gov.in/w/section-177-77 (2026)
6. Income Tax Department, Income-tax Act 2025 s.159 (treaty relief) — https://www.incometaxindia.gov.in/w/section-159-89 (2026)
7. Income Tax Department, Income-tax Act 2025 s.197 (long-term capital gains) — https://www.incometaxindia.gov.in/w/section-197-78 (2026)
8. Income Tax Department, Form 41 FAQs — https://www.incometaxindia.gov.in/documents/d/guest/form-41-faqs ; FAQs on forms under the Income-tax Rules 2026 — https://www.incometaxindia.gov.in/w/faqs-on-forms-as-per-income-tax-rules-2026-1 (2026)
9. HMRC / gov.uk, UK–India synthesised text of the MLI and the 1993 Convention (Arts 11(2), 11(3), 13, 14) (accessed 11 October 2026) — https://www.gov.uk/government/publications/india-tax-treaties/2020-uk-india-synthesised-text-of-the-multilateral-instrument-and-the-1993-double-taxation-convention-in-force
10. Income Tax Department, India–Netherlands synthesised text (Art 13(5)) (accessed 11 October 2026) — https://www.incometaxindia.gov.in/w/netherlands-synthesised-text-1
11. Income Tax Department, India–UAE synthesised text — https://incometaxindia.gov.in/DTAA/Synthesized-text-India-UAE-DTAA.htm
12. EY India, "Delhi Tribunal ruling on whether share buy-back within corporate group is a corporate reorganisation" (Huntsman Investment Netherlands BV, TS-417-ITAT-2026(DEL)) (22 Jun 2026) — https://www.ey.com/en_in/technical/alerts-hub/2026/06/delhi-tribunal-ruling-on-whether-share-buy-back-within-corporate-group
13. RSM India, "Key amendments in Finance Act 2026 vis-à-vis Finance Bill 2026" (Mar 2026; s.69(2)(b), 12% surcharge, s.68 limitation) — https://www.rsm.global/india/sites/default/files/media/thumbnails/RSM%20India%20Newsflash%20-%20Key%20Amendments%20in%20Finance%20Act%202026%20vis-%C3%A0-vis%20Finance%20Bill%202026.pdf
14. Khaitan & Co, Budget 2026 direct tax proposals (2 Feb 2026; promoter base rates 22%/30%, "including non-resident Promoters"; short-term unlisted 35% for non-resident corporates) — https://www.khaitanco.com/sites/default/files/2026-02/KCO%20-%20Budget%202026-Direct%20Tax%20Proposals%20-%202%20February%202026.pdf
15. Taxguru, buy-back taxation under the Income-tax Act 2025 (6 Jul 2026) — https://taxguru.in/income-tax/buy-back-shares-taxability-income-tax-act-2025.html
16. Business Today, "Buyback tax: how India changed the rules three times in 18 months" (3 Sep 2026) — https://www.businesstoday.in/markets/story/buyback-tax-how-india-changed-the-rules-three-times-in-18-months-and-what-investors-need-to-know-553004-2026-09-03
17. Vinod Kothari Consultants, ECB framework (updated 19 Feb 2026) — https://vinodkothari.com/2025/10/easing-fundraising-via-ecbs/
18. King Stubb & Kasiva, "RBI overhauls ECB framework under FEMA 2026" (4 Mar 2026) — https://ksandk.com/newsletter/rbi-overhauls-ecb-framework-under-fema-2026/
19. PCIT v Jupiter Capital Pvt Ltd, Supreme Court, SLP (C) No. 63 of 2025 (reported 2 Jan 2025; Karnataka High Court upheld)
20. IndiaCorpLaw, "Capital reduction: tax conundrums" (23 Sep 2023) — https://indiacorplaw.in/2023/09/23/capital-reduction-tax-conundrums/
21. Treelife, "Repatriating profits from India" (28 Jul 2026) — https://treelife.in/legal/repatriating-profits-from-india/
22. Treelife, "Capital reduction vs dividend on wind-down" (29 May 2026) — https://treelife.in/legal/capital-reduction-vs-dividend-on-wind-down/
23. PwC Worldwide Tax Summaries, UAE — Income determination (participation exemption) (reviewed 9 Sep 2026) — https://taxsummaries.pwc.com/united-arab-emirates/corporate/income-determination
24. Argus Partners, Supreme Court in Tiger Global (16 Jan 2026) — https://www.argus-p.com/updates/updates/supreme-court-denies-tax-treaty-relief-under-india-mauritius-dtaa-for-tiger-globals-flipkartwalmart-exit/
25. EY India, Mauritian Cabinet approves ratification of protocol to India–Mauritius DTAA (22 Jul 2026) — https://www.ey.com/en_in/technical/alerts-hub/2026/07/mauritian-cabinet-approves-ratification-of-protocol-to-india-mauritius-dtaa
26. KPMG TaxNewsFlash, Nestle SA MFN ruling (Oct 2023) — https://kpmg.com/us/en/home/insights/2023/10/tnf-india-notification-required-benefit-under-income-tax-treaty-mfn-clause.html
27. Income Tax Department, Income-tax Act 2025 s.200 (22% domestic-company regime) — https://www.incometaxindia.gov.in/w/section-200-77 (2026)
28. Vinod Kothari Consultants, "Buyback taxation rationalised with limited relief to promoter shareholders" (Feb 2026; promoter of unlisted company = s.2(69) promoter or >10% holder; 22% domestic company / 30% others) — https://vinodkothari.com/2026/02/buyback-taxation-rationalised-with-limited-relief-to-promoter-shareholders/
29. IRS, International Practice Unit, Section 245A dividends received deduction — https://www.irs.gov/pub/fatca/int_practice_units/section-245a-dividend-received.pdf
30. Reserve Bank of India, FEMA (Non-debt Instruments) Rules 2019, consolidated (to 2 Sep 2026; Rules 21(2)(c), 22(2)(b)) — https://rbi.org.in/Scripts/bs_viewcontent.aspx?Id=5083
31. KPMG South Africa, Tax Alert Issue 11, ratification of the new protocol to the Mauritius–India tax treaty (Aug 2026; "gazetted in Mauritius 8 August 2026 … entered into force on 10 August 2026") — https://assets.kpmg.com/content/dam/kpmgsites/za/pdf/2026/08/kpmg-tax-alert-issue-11-ratification-of-the-new-protocol-to-the-mauritius-india-tax-treaty-2026.pdf
32. Forvis Mazars Mauritius, "India–Mauritius DTAA Protocol: the Principal Purpose Test" (11 Sep 2026) — https://www.forvismazars.com/mu/en/services/tax/tax-insights/india-mauritius-dtaa-protocol ; Sovereign Group, "Mauritius Cabinet approves pending Protocol" (10 Sep 2026, updated 20 Sep 2026) — https://www.sovereigngroup.com/news/mauritius-cabinet-approves-pending-protocol-to-tax-treaty-with-india/ ; ELP, "The India–Mauritius DTAA Protocol and the PPT" (Jul 2026; Art 27B) — https://elplaw.in/wp-content/uploads/2026/07/The-India-Mauritius-DTAA-Protocol-and-the-Principal-Purpose-Test-Treaty-Entitlement-Substance-and-the-Post-2017-Investment-Landscape.pdf (all accessed 12 October 2026)
33. Income Tax Department, Income-tax Act 2025 s.69 (s.69(1) gain on buy-back is capital gains; s.69(2) additional income-tax for a promoter on a buy-back under s.68 Companies Act 2013 — short-term gains under s.196: 2% domestic company / 10% others; long-term gains under ss.197–198: 9.5% domestic company / 17.5% others; s.69(3) promoter of an unlisted company = Companies Act s.2(69) promoter or a person holding directly or indirectly more than 10%; sub-sections (2)–(3) substituted by Act No. 4 of 2026 with effect from 1 Apr 2026) (accessed 12 October 2026) — https://www.incometaxindia.gov.in/w/section-69-127
34. Reserve Bank of India, Foreign Exchange Management (Borrowing and Lending) (First Amendment) Regulations 2026, FEMA 3(R)(5)/2026-RB (dated 9 Feb 2026, gazetted 16 Feb 2026; Schedule I) — https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13306&Mode=0 ; A.P. (DIR Series) Circular No. 22 of 16 Feb 2026 — https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13305&Mode=0 (accessed 12 October 2026)
35. Reserve Bank of India, Master Direction — External Commercial Borrowings, Trade Credits and Structured Obligations (updated 8 Sep 2026; para 6.1) — https://www.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=11510 (accessed 12 October 2026)
36. Reserve Bank of India, Foreign Exchange Management (Overseas Investment) Directions 2022 (22 Aug 2022; para 1(viii) and para 27(2)) — https://www.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=12381 (accessed 12 October 2026)
37. Reserve Bank of India home page, FBIL reference rates as at 1 pm, 12 Oct 2026: USD 95.7485, GBP 126.9185, EUR 107.3022 — https://www.rbi.org.in/ (accessed 12 October 2026)
38. Income-tax Act 2025, s.2(40) "dividend" (reproduction; sub-clause (d) distribution on reduction of capital to the extent of accumulated profits) (accessed 12 October 2026) — https://eztax.in/income-tax-act-2025/section-2
39. Income-tax Act 2025, s.393(2) (reproduction; Sl. Nos. 2–4 legacy interest entries for pre-1 Jul 2023 borrowings and IFSC bonds; Sl. No. 17 residual) (accessed 12 October 2026) — https://eztax.in/income-tax-act-2025/section-393
40. Reserve Bank of India, FEMA 395/2019 (Mode of Payment and Reporting of Non-Debt Instruments) consolidated to 13 Jun 2026 (FC-TRS within 60 days of transfer or receipt of funds, whichever is earlier) — https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11723&Mode=0 (accessed 12 October 2026)
41. PwC Worldwide Tax Summaries, India — Taxes on corporate income (reviewed 11 May 2026; foreign company 36.40% / 37.13% / 38.22%; MAT 14% from tax year 2026-27) — https://taxsummaries.pwc.com/india/corporate/taxes-on-corporate-income (accessed 12 October 2026)
42. ATB Legal, FDI in India: rules, routes and approvals for foreign investors (2026) (October 2026) — https://atblegal.com/blog/foreign-investment-in-india/fdi-approval-process/

Disclaimer: This article is general information, not legal or tax advice. Indian, treaty and home-country rules change frequently and outcomes depend on facts; verify against current law and take advice before acting.