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France to India · PE

Permanent establishment risk for French companies in India

CA Utsav Dogra, Chartered Accountant, ICAI M. No. 542375 · Updated

In brief

A French company that has a fixed place, a dependent agent or a long project in India can become taxable in India on the profits attributable to it. Under the India–France tax treaty: Fixed place and site permanent establishments; the 2026 protocol would add a services PE.

What is specific to French companies

Today's treaty uses fixed place and site PE rules; the pending protocol would add a services PE.

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Questions

Does having a subsidiary create a PE for the parent?

Not by itself. Risk arises from what parent staff or the subsidiary's people do on the parent's behalf.

General information as at 5 November 2026, not advice for a particular case. Indian and French rules change often; confirm the current position before acting. French law points should be confirmed with a French adviser.

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