How are App Store and Google Play earnings treated for GST and income tax in India?

Indian app and game developers, from solo indie studios to SaaS companies with mobile apps, earn through the Apple App Store and Google Play. The stores collect from users worldwide, keep a commission, and pay the developer. The GST question is whether the developer supplies to the store or to each user, and the answer is not the same for every store or every country.¹²

This guide sets out what each store's contract says, how that maps to GST, where practitioners disagree, and the income tax and FEMA points. It reflects terms checked on 28 October 2026.¹²³

What is the GST position of App Store and Google Play income?

The GST position of App Store and Google Play income depends on each store's contract and on where the buyer is, because the contract decides who the developer's recipient is.¹² Both stores describe the developer as the principal and the store as an agent, but the contracting entity and its role change by region.¹²

What does Apple's agreement say about who sells your app?

Apple's Developer Program License Agreement says the developer appoints Apple and Apple subsidiaries as agent or commissionaire for the marketing and delivery of paid apps, and that the developer remains the principal, under Schedule 2, sections 1.1 and 1.3.¹ Which role Apple plays depends on the buyer's region, listed in Exhibit A to Schedule 2:¹

The table is taken from Exhibit A to Schedule 2.¹ The agreement defines a commissionaire as "an agent who purports to act on their own behalf and concludes agreements in their own name but acts on behalf of other persons".¹

• Tax collection: section 3.2 of Schedule 2 refers to Exhibit B, which lists regions where Apple "shall collect and remit to the competent tax authorities" the taxes on sales to end users. India is on that list without a qualifying footnote.¹
• Commission: Apple's commission under section 3.4 is 30% of the price, or 15% for auto-renewing subscription renewals after a subscriber's first year.¹

What does Google Play's agreement say about who sells your app?

Google Play's Developer Distribution Agreement, effective 15 September 2025, says the developer appoints Google as its "agent or marketplace service provider" (section 3.1), and that Google, "acting as Your agent, and with You acting as a principal", is the merchant of record for products sold to users in listed countries (section 3.4).² The contracting Google entity depends on where you distribute (section 2.1).² Section 3.5 adds that where Google collects and remits transaction taxes, the developer "may recognize a deemed supply from You to Google solely for Transaction Tax purposes if required by applicable law".²

GST TCS (tax collection at source) is the tax that an electronic commerce operator collects under section 52 of the CGST Act.⁷

Who does the App Store and Google Play GST treatment apply to?

The App Store and Google Play GST treatment differs for India-based developers and developers outside India, and for sales to users abroad and users in India.¹³

Your store reports show which region each sale falls in.

How do you work out GST on App Store and Google Play income?

You work out GST on App Store and Google Play income by identifying the store entity and recipient for each region, then applying the place of supply and export rules, and the reverse charge on the commission.¹²⁴⁵⁸

1. Identify the store entity by region: Apple's Exhibit A and Google's section 2.1 set the contracting entity.¹²
2. Identify the recipient: the person liable to pay the consideration under section 2(93) of the CGST Act.⁷
3. Check place of supply and export conditions: for recipients outside India, the place of supply is the recipient's location under section 13(2) or 13(12), and the supply can be an export if all five conditions of section 2(6) of the IGST Act are met.⁴⁵
4. Treat India sales separately: follow the store's description of who charges and remits GST.¹³
5. Account for GST on the commission: pay IGST under reverse charge where the store entity is outside India.⁸
6. Reconcile TCS and withholding: claim credit for what Google deducts.³

This is a question for a chartered accountant, with your store reports in hand.

Who is the Indian developer's GST recipient for app store sales?

The developer's recipient is the person liable to pay the consideration under section 2(93) of the CGST Act, and that is where the store contracts make GST contested.⁷ Three readings are argued:

1. End user as recipient: both stores say the developer is the principal and the store is an agent.¹² On this reading, a sale to a user in Canada is a supply to a recipient outside India.
2. Store entity as recipient: at least where it acts as commissionaire in its own name (Apple outside the agency regions) or where Google's agreement points to a deemed supply to Google.¹²
3. Mixed: depending on the region and on whether the store collects tax as a deemed supplier. Section 14 of the IGST Act deems an intermediary outside India that arranges OIDAR supplies to Indian consumers, collects payment and sets terms to be the supplier for those sales.⁶

For sales to users abroad, readings 1 and 2 often lead to the same result: the recipient is outside India and the supply can be an export.⁴⁵ Zero-rated exports carry no GST, under section 16.⁹

What happens if the GST recipient for India sales is read differently?

If the GST recipient for India sales is read differently, the same sale can be either a taxable domestic supply by the developer or a supply to an entity abroad with the store remitting GST.¹³

• End user read as recipient: the Indian developer's sale is domestic and taxable; Google's page treats India-based developers this way.³
• Apple's commissionaire read as recipient: the developer's supply is to an entity in Ireland and Apple remits GST on the sale to the Indian user.¹

Pick one reading with your adviser and apply it consistently across GST and income tax.

What rates and documents apply to App Store and Google Play income?

The rates that apply to App Store and Google Play income are the store's commission, GST on that commission under reverse charge, and the presumptive and FEMA limits for the developer.¹⁸¹⁰¹³

See reverse charge on imported SaaS tools and services.

How is App Store and Google Play income taxed in India?

App store earnings are business or professional income for a resident developer under the Income-tax Act, 2025, in force from 1 April 2026.¹⁰

• Presumptive scheme: a resident individual or partnership firm (not an LLP) in a specified profession can use section 58(2), Table row 3 (formerly section 44ADA): 50% of gross receipts deemed as profit, with a limit of ₹50 lakh, or ₹75 lakh if cash receipts are 5% or less.¹⁰ Information technology is listed in section 62(4).¹⁰ A studio selling games may want advice on whether its activity is a profession or a business.
• Gross receipts: whether gross receipts are the user price or your net proceeds after commission follows from the same recipient question as GST; be consistent across GST and income tax.
• Tax deducted in India: Google says it deducts withholding tax on paid app sales by India-based developers; claim credit for it in your return.³
• Foreign tax credit: if tax is withheld abroad, claim credit using Form 44 under rule 76 of the Income-tax Rules, 2026 from tax year 2026-27.¹¹

What FEMA rules apply to App Store and Google Play payouts?

Store payouts for sales abroad are export receipts under the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, in force from 1 October 2026.¹² The realisation period is nine months from the invoice date.¹³ Every exporter of services gives an Export Declaration Form (EDF), but how the EDF applies to monthly store settlements, where the developer issues no invoice to each user, is not yet clear in practice; ask your bank.¹²

What are the common mistakes with App Store and Google Play income?

The common mistakes with App Store and Google Play income are treating every store sale the same way and measuring gross receipts differently for GST and income tax.¹³¹⁰

• One rule for every region: Apple acts as agent in some regions and commissionaire in others.¹
• Ignoring GST on the commission: the fee is a separate service, generally under reverse charge from an entity abroad.⁸
• Not claiming deducted tax: claim credit for Google's withholding tax and GST TCS.³
• Inconsistent gross receipts: use the same measure across GST and income tax.

For collecting payouts, see receiving App Store payments and receiving Google Play payments.