The French Senate has approved a bill to ratify a protocol amending the 1992 tax treaty between France and India, sending the measure to the National Assembly for consideration.
The French Senate approved the bill on 27 October 2026, ratifying the protocol signed on 18 February 2026.
The protocol is an amendment to the 1992 tax treaty and brings it in line with OECD BEPS standards, alongside several other changes. The bill now goes to the National Assembly, the lower house.
New Articles 11 (Dividends) and 14 (Capital Gains) will apply after a two-year gap, counted from the end of the year in which the protocol enters into force. A new Article 13 (Royalties and Fees for Technical Services) will apply retroactively to amounts paid from 1 January 2024.
The protocol will enter into force the day after the instruments of ratification are exchanged.
It will generally apply in France from 1 January of the year following its entry into force, and in India from 1 April of the year following its entry into force.
The amendments on Mutual Agreement Procedure, Exchange of Information, and Assistance in the Collection of Taxes will apply from the date of entry into force.
