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India-France DTAC Amended: Capital Gains Taxing Rights

26 February 20261 min read
INTERNATIONAL AFFAIRSIndia-France DTACAmended: CapitalGains TaxingRights26 February 2026safalsetu.com

Why in the news

The Government of India and France signed a protocol in February 2026 to change the tax treaty between them, which dates from 1992. The changes touch capital gains and the MFN clause.

Key facts

  • Treaty: Double Taxation Avoidance Convention (DTAC) between India and France, signed in 1992.
  • Change one: capital gains taxing rights lie with the country where the company is resident.
  • Change two: the Most-Favoured-Nation (MFN) clause is removed.
  • Reason for the second change: fewer tax disputes and greater clarity.

Amendments at a glance

ProvisionEffect of the protocol
Capital gainsTaxed by the resident country of the company
MFN clauseDeleted
AimReduce disputes, improve clarity

Exam angle

  • Parties: Government of India and France.
  • Original treaty year: 1992.
  • Full form: DTAC is the Double Taxation Avoidance Convention; MFN is Most-Favoured-Nation.

Test yourself

1. Which year's India-France Double Taxation Avoidance Convention was amended by a protocol in February 2026?

The convention being amended was signed in 1992.

2. Which clause was removed from the India-France DTAC under the new protocol?

The protocol removes the MFN clause to reduce disputes.

3. Under the amended India-France DTAC, who gets taxing rights over capital gains?

Taxing rights go to the country where the company is resident.