When was the India-France Double Taxation Avoidance Convention amended?

The India-France Double Taxation Avoidance Convention was amended through an protocol signed on February 23, 2026.

What are the new tax rates for dividends between India and France?

The amended protocol imposes a split tax rate of 5% for holdings of at least 10% of the capital and 15% for all other dividend holdings.

How does the new India-France tax protocol affect investments?

The protocol aims to provide greater tax certainty, boost the flow of investment and technology, and strengthen the economic relationship between India and France.

Home / Business and Economy / India-France Tax Treaty Gets Major Overhaul

India-France Tax Treaty Gets Major Overhaul

23 Feb

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Summary

India and France amended the 1992 Double Taxation Avoidance Convention.
New protocol modifies tax rates on dividends and capital gains.
Changes aim to boost investment, technology, and personnel flow.

India-France Tax Treaty Gets Major Overhaul

As of February 23, 2026, India and France have entered into an amending protocol to their Double Taxation Avoidance Convention (DTAC), originally established in September 1992. This significant update aims to bolster tax certainty within the economy and foster increased investment, technology transfer, and the movement of personnel between the two countries, thereby strengthening their economic relationship.

The revised protocol introduces changes to taxation on dividends, replacing the previous flat 10% rate with a split system: 5% for holdings of at least 10% of the capital and 15% for all other holdings. Additionally, the definition of 'Fees for Technical Services' has been updated to align with the India-US Double Taxation Avoidance Agreement, and the scope of Permanent Establishment has been broadened to include 'Service PE'.