India-France DTAC Amended: Capital Gains Taxing Rights
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
| Provision | Effect of the protocol |
|---|---|
| Capital gains | Taxed by the resident country of the company |
| MFN clause | Deleted |
| Aim | Reduce 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.