India-France DTAA
Treaty signed: September 29, 1992 | Effective from: August 1, 1994
● Live · Rates served from /api/tax-rules/dtaa/FR
Dividends
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Interest
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Royalties
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Capital Gains
Fees for Technical Services
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Key Treaty Provisions
- Comprehensive treaty covering all income types; particularly relevant for pharma (Sanofi, L'Oreal) and luxury goods sectors
- France has ratified MLI; PPT and other MLI provisions apply
- Dividends: 10% for all shareholders (no higher rate for controlling shareholders)
- Capital gains on Indian shares: taxable in India
- Employment income: 183-day rule applies for temporary visitors
Frequently Asked Questions
What is the TDS rate on royalties paid to a French software company by an Indian licensee?▾
Under the India-France DTAA, royalties (including software licensing fees where the payer is in India) are taxable at 10%. The French company must furnish TRC from the Direction Générale des Finances Publiques (DGFIP) and Form 10F to claim the 10% rate.
Does India tax French-company dividends paid to Indian residents?▾
Indian residents receiving dividends from French companies are taxed in India at their applicable slab rate (dividends are taxable income in India). France also withholds tax on dividends per its domestic law. The French tax can be credited in India under the relief of double taxation article.
How does India-France DTAA apply to a French consultant working in India?▾
If the French consultant stays in India for less than 183 days in a 12-month period and is paid by a French employer not bearing the cost through an Indian PE, the income is not taxable in India. Beyond 183 days, Indian taxation applies from day one of the India visit.
Browse all articles
20 articlesArticle 1 of the India-France DTAA governs persons covered.…
Article 4 of the India-France DTAA governs resident.…
Article 5 of the India-France DTAA governs permanent establishment.…
Article 7 of the India-France DTAA governs business profits.…
Article 8 of the India-France DTAA governs shipping, inland waterways, and air transport.…
Article 9 of the India-France DTAA governs associated enterprises.…
Dividends paid by a company resident in one State to a resident of the other State may be taxed in the recipie…
Interest arising in one State and paid to a resident of the other may be taxed in the recipient's State, with …
Royalties paid to a resident of the other State may be taxed in the recipient's State; the source State retain…
FTS - payments for managerial, technical, or consultancy services - are taxed at the treaty rate where a speci…
Article 13 allocates taxing rights over capital gains between India and France.…
Article 14 of the India-France DTAA governs independent personal services.…
Article 15 sets the taxing rights for salaries earned by an employee of one State who works in the other.…
Article 17 of the India-France DTAA governs artistes and sportspersons.…
Article 18 of the India-France DTAA governs pensions.…
Article 19 of the India-France DTAA governs government service.…
Article 23 sets out the mechanism by which double taxation is eliminated - typically through a foreign tax cre…
MAP allows the competent authorities of India and France to resolve disputes - particularly transfer pricing d…
Allows the competent authorities to exchange information necessary to apply the treaty or domestic tax laws.…
Treaty benefits are denied where the principal purpose of the transaction was to obtain them.…
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