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Germany

NRE and NRO interest when you are a German tax resident

You have been told NRE interest is tax-free, but that holds only in India, not on your German return.

You keep money in Indian NRE and NRO accounts, and you understand NRE interest to be tax-free. In India it is. But you are a tax resident of Germany, which taxes worldwide income, and interest is one of the few things the treaty lets Germany tax. So your NRE interest is fully taxable in Germany, and because India took nothing, there is nothing to credit against the German bill. And you have to declare it yourself, because the Indian bank does not withhold German tax. Here is how NRE and NRO interest really sit for a German resident.
Last reviewed: 26 July 20266 min readReviewed by Preetesh Maloo, CA

The short answer

NRE interest is exempt in India under Section 10(4), but that is an Indian rule. Interest is one of the few kinds of income the treaty lets Germany tax with a credit, so a German resident pays the 25% flat tax on capital income plus the solidarity surcharge, about 26.375%, on both NRE and NRO interest. On NRO interest, where India charges tax, Germany credits the 10% treaty rate. On NRE interest, India charges nothing, so there is no credit and you bear the full German tax. A saver's allowance of €1,000, or €2,000 for a couple, applies first, and because the Indian bank does not withhold German tax, you declare the interest yourself on your German return.

References on this page

  • NRE interest is exempt in India (Section 10(4)) only while you are non-resident; India deducts no TDS
  • Germany taxes interest at the flat 25% capital-income tax plus solidarity surcharge (about 26.375%)
  • NRO interest: TDS under Section 195, capped at the treaty rate of 10%, which Germany credits
  • NRE interest: no India tax was paid, so there is no German credit, and you declare it yourself (no bank withholding)

Tax-free NRE stops at the German border

Interest on an NRE account is exempt in India under Section 10(4) while you hold non-resident status, and the Indian bank deducts no tax. That is the whole basis of the tax-free reputation, and inside India it is right.

Germany does not recognise it. A German resident is taxed on worldwide income, and interest is specifically a kind of income the treaty allows Germany to tax while giving a credit for any India tax. So the NRE interest is taxed in Germany at the flat 25% tax on capital income plus the 5.5% solidarity surcharge on that tax, about 26.375% in all, and any church tax. Because India levied nothing, there is no India tax to credit, so you bear the full German charge. The saver's allowance, €1,000 for a single person or €2,000 for a married couple, is set against your capital income first, but beyond that the NRE interest is taxed in full.

NRO interest, and declaring it yourself

NRO interest is taxable in India. The bank deducts TDS under Section 195 at about 31% by default, but the India-Germany treaty caps the tax on interest at 10%, which you get by filing a tax residency certificate and Form 10F with the bank before the interest is paid. Germany then taxes the NRO interest at its flat rate too, and credits the 10% India tax, so the double tax on NRO interest is largely relieved.

One practical point applies to both accounts: the Indian bank does not withhold German tax, so unlike a German bank account, this interest is not settled at source. You must declare it yourself on the capital-income part of your German return. Leaving foreign interest off the German return is a common and risky omission, because the German tax office increasingly receives account information internationally. So the NRE interest in particular has to be actively reported, since nobody withholds it for you and it is fully taxable.

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What's involved

What the CA actually does

  1. 1

    We flag the NRE reality

    We make sure your NRE interest is reported on the German side, since it is tax-free only in India, so it is not missed and later penalised.

  2. 2

    We cap the NRO TDS at the treaty rate

    We file your tax residency certificate and Form 10F so the bank deducts 10% on NRO interest, matching what Germany will credit.

  3. 3

    We reclaim any over-deduction

    Where the bank took the full rate, we file the Indian return to recover the excess above 10%, which Germany will not credit.

  4. 4

    We provide the figures to declare

    We give you the NRE and NRO interest and the India tax paid, in the form your German accountant needs for the capital-income return.

What to have ready

Documents you'll typically need

  • Your NRE and NRO interest for the year
  • Any TDS the bank deducted on NRO interest
  • Your tax residency certificate and Form 10F, if filed
  • Your PAN and German tax details

Frequently asked questions

Common questions

NRE and NRO interest on your German return?

Tell us your balances and the TDS. A practising CA will cap the NRO tax and give you the figures to declare on a free call, no obligation.

No card, no obligation. All certification and filing work is handled by ICAI-registered practising Chartered Accountants.