France’s Council of Ministers approved a protocol amending the income and capital tax treaty on 16 September 2026. The draft approval law was subsequently submitted to the Senate for further approval.
France’s Council of Ministers approved on 16 September 2026 a protocol amending the income and capital tax treaty of 1992, as amended by the 2000 notification. The protocol was signed in February 2026 and represented the first amendment to the treaty.
The protocol includes changes aimed at aligning the treaty with OECD BEPS standards, along with amendments covering the Mutual Agreement Procedure, Exchange of Information, and Assistance in the Collection of Taxes.
The protocol will enter into force the day after France and India exchange their ratification instruments. Its provisions will generally apply in France from 1 January of the year following its entry into force and in India from 1 April of the following year.
Earlier, India’s Central Board of Direct Taxes announced that an amending protocol to the 1992 income and capital tax treaty had been signed on 17 February 2026.
