• India and France signed a Protocol amending their 1992 Double Taxation Avoidance Convention (DTAC), modernising the three-decade-old framework.
• The revised treaty reduces dividend taxation for significant investors while expanding India’s rights to tax capital gains and cross-border share transfers.
• The amendments align with India’s broader treaty renegotiation strategy emphasising source-based taxation, anti-avoidance safeguards, and greater legal clarity.
• French multinationals and portfolio investors may need to reassess dividend repatriation, exit strategies, and cross-border tax structuring under the updated regime.
