TDS on Foreign Company

In this case the taxability of income need to be verified. The existance of DTAA between India & Germany need to be considered. As per my view the payment will not accrue any income taxable in India. So you need not deduct TDS u/s 195. Still more detailed perusal of DTAA is needed.

You may use this link to view DTAA

https://law.incometaxindia.gov.in/DIT/File_opener.aspx?fn=https://law.incometaxindia.gov.in/Directtaxlaws/cbdt/dta/A1_Germany.htm

The following is some useful extract from DTAA from India & Germany

Words ‘subject to the provisions of paragraph (3)’ in article III(1) of Double Taxation Avoidance Agreement (between Federal Republic of Germany and India) would indicate that while ‘industrial or commercial income’ of the foreign enterprise are not taxable in India, the rents, royalties, interests, dividends, etc., derived by the foreign enterprise from sources in India are taxable - CIT v.Visakhapatnam Port Trust [1983] 144 ITR 146 (AP).