Update - Amending Protocol to Tax Treaty between France and India

The amending protocol to the 1992 tax treaty between France and India was signed on 18 February 2026. The protocol is the first to amend the treaty and includes the following changes:

• The preamble is replaced in line with OECD BEPS standards;
• Article 5 (Permanent Establishment) is amended with updated provisions, including that a permanent establishment (PE) will be deemed constituted when an enterprise furnishes services in a Contracting State through employees or other engaged personnel if…