Money out: repatriation

Getting Money Out of India to a Russian Parent: Dividends at 10%, Service Fees, Royalties, Interest and Loan Repayments

By Abhishek Jaiin, Chartered Accountant (ICAI membership no. 544646), AU Corporate · Last updated 26 October 2026

Short answer

A Russian parent can take money out of its Indian subsidiary as dividends, service fees, royalties, interest, loan repayments, buy-backs or sale proceeds. The treaty caps Indian withholding at 10% on dividends, interest, royalties and fees for technical services when the paperwork is in place, against a domestic rate of about 20% plus surcharge and cess on dividends to non-residents. The tax is the easy part. The route is harder: the receiving Russian bank, intermediaries and currency must be acceptable to the Indian bank, and payments to related parties are scrutinised, so keep contracts, evidence of service and arm's length support.

← Back to the complete guide: How to Set Up a Subsidiary in India from Russia

Key facts

Dividends10% treaty rate with a Russian beneficial owner taxable in Russia; paid from distributable profits after audit and shareholder approval
Service feesFees for technical services at 10% under the treaty if technical, managerial or consultancy; GST reverse charge applies
Royalties10%; licence agreement and valuation required
Interest10%; ECB limits; interest limitation rule
Loan principalNo tax on principal; follows the ECB schedule
PaperworkRussian tax residency certificate, Form 41, no-PE declaration, Form 145 (previously 15CA), Form 146 (previously 15CB) where needed
RouteReceiving bank and currency must pass the Indian bank's sanctions and compliance checks
Russian sideTax with credit for Indian tax; currency control and notification rules; confirm with a Russian adviser

The routes compared

RouteIndian tax on the outflowRussian resultWatch for
Dividends10% under the treaty, against about 20% plus surcharge and cess domesticallyPossibly 0% for qualifying holdings or taxed with credit; confirmDistributable profits; Form 41 before payment; MLI principal purpose test
Service fees10% if fees for technical services; nil if business profits without a PETaxable with creditEvidence of service, arm's length price, GST reverse charge
Royalties10%Taxable with creditLicence agreement, valuation, transfer pricing
Interest10%; limits on cost and amountTaxable with creditECB ceiling; interest limitation rule
Loan principalNone on principalNot incomeMaturity, registration and payment route
Buy-back or sale proceedsCapital gain tax; buy-back treatment depends on current lawTaxed with credit as per Russian rulesTax on gains in India; see exit guide

Paying a dividend

  1. Prepare audited accounts and confirm distributable profits under the Companies Act.
  2. The board recommends and shareholders approve the dividend.
  3. Collect from the Russian parent: tax residency certificate, Form 41, beneficial ownership and no-PE declaration.
  4. Deduct Withholding Tax at the treaty rate under Section 393 of the Income-tax Act, 2025, and deposit it by the 7th of the following month.
  5. Confirm the receiving bank and currency with the Indian bank in advance, then remit with Form 145 (and Form 146 if the bank requires a chartered accountant's certificate).

Service fees, royalties and recharges

  • Payments for management, technical or consultancy services are fees for technical services at 10% under the treaty if the paperwork is in place, plus GST on reverse charge.
  • A recharge of salaries for seconded staff is a service fee; apply Withholding Tax and transfer pricing. See Russian employees in India.
  • Pay only for services actually received, and keep the contract, invoices and evidence of benefit.
  • A royalty needs a written licence agreement, a clear scope and arm's length pricing. See transfer pricing.

Remittance paperwork

DocumentWhenPurpose
Tax residency certificate and Form 41Before the first payment each yearClaim treaty rate
Beneficial ownership and no-PE declarationBefore paymentSupport treaty claim and principal purpose test
Form 145 (previously 15CA)Each foreign remittanceOnline declaration to the tax department
Form 146 (previously 15CB)Where required for the remittanceChartered accountant's certificate
Withholding Tax return and certificateQuarterly return; certificate to the payeeRussian credit and records

Russian side

Russian tax and currency control on receipts are for your Russian adviser. See Russian parent obligations. ₹10 lakh is about RUB 845,000 at an indicative ₹1.18 per rouble (27 October 2026 market rate; check the live rate before remitting).

Official sources

Check the rules at the primary sources: Income Tax Department (India), Reserve Bank of India, Ministry of Corporate Affairs, Federal Tax Service (Russia), Bank of Russia and the Ministry of External Affairs (India).

Frequently asked questions

What is the withholding tax on dividends paid from India to a Russian parent?

10% of the gross amount under the treaty if the Russian company is the beneficial owner and the paperwork is in place. The domestic rate is about 20% plus surcharge and cess.

Which forms do I need to send money to Russia?

Form 145 for the remittance, and Form 146 where a chartered accountant's certificate is needed, along with Form 41 and the tax residency certificate for treaty rates.

Can I pay a management fee to Russia?

Yes if it is for real services at an arm's length price, with Withholding Tax at 10% as fees for technical services under the treaty and GST on reverse charge.

Can the subsidiary pay dividends from capital?

No. Dividends must come from distributable profits as the Companies Act requires.

Can I repay a loan to Russia?

Yes, following the registered ECB schedule through the bank. Principal is not taxed, but interest is subject to Withholding Tax.

Can any bank receive the money in Russia?

The Indian bank must be willing to send to the receiving bank and currency. Sanctions screening can restrict the options.

What if the Russian company is only a conduit?

The MLI principal purpose test and the general anti-avoidance rule can deny treaty relief. Keep commercial substance in Russia.

See all 157 FAQs →Plain answers on incorporation, FEMA, tax, hiring and exit.

India-Russia Double Taxation Agreement Explained: 10% Dividends, Interest, Royalties and Technical Fees, PE Rules and the MLI

The India-Russia tax treaty explained for a Russian parent: 10% dividends, interest, royalties and fees for technical services, permanent establishment, share gains, credit method, the MLI principal purpose test and how to claim treaty rates.

Read the guide →

Transfer Pricing between India and Russia: Arm's Length Pricing, Goods and Services Flows, Documentation and Safe Harbours

Transfer pricing for a Russian group with an Indian subsidiary: arm's length rules, accountant's report, master file and local file, supply of equipment and components, management fees, royalties, advance pricing agreements and safe harbours.

Read the guide →

Funding Your Indian Subsidiary from Russia: Equity, Preference Shares, External Borrowing, FEMA Reporting and the Remittance Route

How a Russian parent can fund an Indian company: equity and preference share pricing, 60-day allotment and FC-GPR rules, ECB, loans, FLA return, the remittance route through banks acceptable to India and Russian clearance.

Read the guide →

Sanctions, Banking and Payment Channels for a Russian Parent and Its Indian Subsidiary: Screening, Special Rupee Accounts and Bank Due Diligence

The practical gate for Russian investors in India: US, EU and UK sanctions screening, the 50% ownership rule, Indian bank due diligence, settlement channels including rupee vostro accounts, why non-dollar payments are not a safe harbour and a compliance checklist.

Read the guide →

Sources

← Back to the complete guide

Last updated 26 October 2026. General information only, not legal or tax advice. Indian and Russian rules change often; confirm current requirements before acting.

Talk to AU Corporate

Sending Profits Back to Russia?

Tell us the dividend, fee, royalty or interest you plan to pay, and we'll map the treaty rate, the residence certificate and the remittance route.

  • • Company incorporation and entity selection
  • • FDI, FEMA and regulatory guidance
  • • Tax, banking and post-incorporation support