Tax Treaty: France to India

The India–France tax treaty: rates, permanent establishment and gains

CA Utsav Dogra, Chartered Accountant, ICAI M. No. 542375 · Updated 5 November 2026

In brief

Under the India–France tax treaty (Convention of 1992), India's tax on payments to a French resident is capped at 10% on dividends, 10% on interest and 10% on royalties. Technical fees: 10%. A protocol signed in February 2026 would set dividends at 5% (10%+ holding) or 15%, once ratified.

What is specific to French companies

The 1992 India–France convention caps dividends, interest, royalties and technical fees at 10%. A protocol signed in February 2026 would set dividends at 5% or 15% and add a services PE, once ratified.

Treaty rates

Income	Indian tax under the treaty
Dividends	10%
Interest	10%
Royalties	10%
Technical service fees	Technical fees: 10%.
Gains on Indian shares	Depends on the facts today; the 2026 protocol would let India tax gains on Indian shares.

Permanent establishment

Fixed place and site permanent establishments; the 2026 protocol would add a services PE.

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Questions

Does the treaty always beat Indian domestic rates?

The lower of the treaty and domestic rate applies, provided the recipient is the beneficial owner and holds a valid residency certificate.

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.