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India and France updated their tax treaty to align with OECD rules, enhancing cooperation and curbing profit shifting.
India and France have updated their 1992 Double Taxation Avoidance Convention, introducing a tiered dividend tax, removing the Most-Favoured-Nation clause, and granting the country of company residence full taxing rights on capital gains.
The agreement expands the definition of permanent establishment to include service-based presence, aligns fees for technical services with India’s U.S. treaty, and strengthens information sharing and tax collection cooperation.
It incorporates OECD BEPS anti-abuse measures to combat profit shifting.
The changes aim to reduce treaty shopping, enhance tax certainty, and boost investment between the two nations.
The protocol takes effect after both countries complete domestic procedures.
India y Francia actualizaron su tratado fiscal para alinearlo con las normas de la OCDE, mejorando la cooperación y frenando la transferencia de ganancias.