India and France have signed an updated protocol to their Double Taxation Avoidance Convention (DTAC). This significant revision introduces new rules for taxing capital gains, giving full taxing rights to the country where the company whose shares are sold is resident. It also modifies dividend taxation rates and updates definitions for technical services and permanent establishments. The protocol aims to enhance tax certainty, boost investment, and strengthen economic ties between the two nations.
The Governments of India and France have signed an amending protocol to update the long-standing India-France Double Taxation Avoidance Convention (DTAC), marking a significant step toward strengthening bilateral tax cooperation and investment flows.
The protocol was signed during the recent visit
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The protocol aims to update the India-France Double Taxation Avoidance Convention (DTAC), strengthen bilateral tax cooperation, and facilitate investment flows between the two countries.
The protocol grants full taxing rights for capital gains arising from the sale of shares to the jurisdiction where the company is a resident.
Dividend taxation has been modified from a single 10% rate to a split rate: 5% for those holding at least ten percent of the capital, and 15% for all other cases.
Yes, the definition of 'Permanent Establishment' has been expanded to include 'Service PE'.
The updated provisions and a new Article on Assistance in Collection of Taxes will enable a seamless exchange of information and strengthen mutual tax cooperation between India and France.
The changes will take effect after the completion of internal procedures in both India and France, according to the terms agreed between the countries.