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Special Income

Being a partner in an Indian firm or LLP as an NRI

Your profit share is exempt, your interest and remuneration are taxable, and a new TDS now bites.

You are, or are becoming, a partner in an Indian partnership firm or LLP while living abroad, and you want to know how your income from it is taxed, and whether you are even allowed to be a partner. The answers are mostly favourable: your share of the firm's profit is tax-free in your hands, even as an NRI. But the interest and remuneration you draw are taxable, a new tax deducted at source now applies to them, and there are exchange-control conditions on an NRI being a partner. Here is how it works.
Last reviewed: 26 July 20266 min readReviewed by Preetesh Maloo, CA

The short answer

Your share of the firm's or LLP's profit is exempt in your hands under Section 10(2A), because the firm has already paid tax on its profit, and this exemption applies to an NRI partner just as to a resident one. But the interest on your capital and any remuneration or salary you draw as a working partner are taxable in your hands as business income, to the extent the firm was allowed to deduct them. From the 2025-26 financial year a new withholding, Section 194T, requires the firm to deduct 10% on a partner's remuneration and interest above ₹20,000 a year, though whether that or Section 195 applies to a non-resident partner is not yet settled. And you can be a partner, subject to the exchange-control conditions.

References on this page

  • A partner's share of firm/LLP profit is exempt under Section 10(2A), for an NRI partner just as for a resident
  • Interest on capital and remuneration to a working partner are taxable as business income, to the extent the firm could deduct them
  • From FY 2025-26, Section 194T requires 10% TDS on a partner's remuneration and interest over ₹20,000 a year
  • Whether Section 194T or Section 195 applies to a non-resident partner is not yet settled; an NRI can be a partner subject to FEMA

Profit share exempt, interest and remuneration taxed

The good news first, and it applies to you as an NRI. Your share of the profit of an Indian firm or LLP is exempt in your hands under Section 10(2A). The reason is that the firm itself has already paid tax on its whole profit, so taxing the partner's share again would be double taxation. Some guides wrongly say this exemption is only for resident partners; it is not, a non-resident partner's share of the profit is equally exempt.

What is taxable is what the firm pays you as a working partner beyond your profit share: the interest on your capital, and your remuneration or salary. These are taxable in your hands as business income, but only to the extent the firm was allowed to deduct them under the limits in the law, which were raised from the 2025-26 year. Anything the firm could not deduct is not taxed again on you. So your income from the firm splits into an exempt profit share and taxable interest and remuneration.

The new TDS, and being a partner as an NRI

A recent change affects the cash flow. From the 2025-26 financial year, a new provision, Section 194T, requires the firm to deduct 10% TDS on a partner's remuneration, interest, commission or bonus once it exceeds ₹20,000 in the year, whereas before there was no TDS on payments to partners. So you will now see tax withheld on your interest and remuneration from the firm, which you reconcile on your return. For a non-resident partner there is an open question, not yet settled by the department, whether this new Section 194T applies, or whether the non-resident withholding under Section 195 governs instead; the better view is that Section 195 should apply to you, which also preserves any treaty benefit, but it is worth handling with that uncertainty in mind.

On whether you can be a partner at all, you can, subject to the exchange-control rules. An NRI can be a partner in a firm on a non-repatriation basis, provided the firm is not in a barred activity such as agriculture, plantation, real estate as a business, or print media, and can be a partner in an LLP subject to the foreign-investment conditions, with the rule that at least one designated partner of an LLP must be resident in India. A practising CA keeps your profit share exempt, taxes the interest and remuneration correctly, handles the new withholding and the treaty position, and confirms the exchange-control footing.

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What's involved

What the CA actually does

  1. 1

    We keep the profit share exempt

    We make sure your share of the firm's profit is treated as exempt under Section 10(2A), which applies to you as an NRI too.

  2. 2

    We tax the interest and remuneration right

    We tax your interest and remuneration as business income only to the extent the firm could deduct them, not the disallowed part.

  3. 3

    We handle the new TDS

    We deal with the new Section 194T withholding on your partner income, and the open question of whether Section 195 applies to you instead.

  4. 4

    We confirm the FEMA footing

    We check that your partnership is on the right exchange-control basis, non-repatriation for a firm, and the conditions for an LLP.

What to have ready

Documents you'll typically need

  • The partnership deed or LLP agreement
  • Your profit share, interest and remuneration for the year
  • Any TDS the firm deducted
  • Your PAN and residency details

Your destination country can change the details

Requirements differ from one consulate, university and visa route to the next — how recent the figures must be, how long funds must have been held, and which certificates are mandatory. We assemble the documents around the exact checklist you're applying under. To see how India's tax treaty with your country of residence affects related filings, set your country below or compare all 31 countries.

Frequently asked questions

Common questions

A partner in an Indian firm or LLP from abroad?

Tell us your profit share and drawings. A practising CA will tax it right and handle the new TDS on a free call, no obligation.

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