Fashion
India, France seal treaty revamp giving Paris dividend relief, Delhi tax rights
By
Reuters
Published
December 12, 2025
India and France have struck a deal to revise their 1992 treaty which will halve the tax on dividends paid by Indian units to French parents, potentially saving millions for companies with major operations in the South Asian nation, documents show.
In return, India will get to widen its powers to tax share sales by French investors, and revoke the “most favoured nation” status of France that gave it certain tax advantages, according to confidential Indian government documents reviewed by Reuters.
Bilateral trade between India and France stood at $15 billion last year, and Indian Prime Minister Narendra Modi and French President Emmanuel Macron have been forging warmer ties. The two sides have been working to recast their tax treaty since 2024 to modernise it by adapting global standards on tax transparency.
“The proposed amending protocol will boost flow of investment, technology and personnel between India and France, and will provide tax certainty,” said one of the Indian government documents from August. The new treaty could have implications for large French portfolio investors as well as companies like Capgemini , Accor, Sanofi, Pernod Ricard, Danone, and L’Oreal– all of which have expanded their presence in India in recent years.
A key change is that French companies which hold a stake of more than 10% in any Indian entity will have to pay a 5% tax on the dividends they receive, instead of 10% earlier. For minority French shareholdings of under 10% in Indian companies, however, dividend tax will rise from 10% to 15%.
Many French firms’ Indian units like Capgemini Technology Services India, BNP Paribas Securities India and TotalEnergies Marketing India have declared dividends in the past, their Indian regulatory disclosures show. The Capgemini unit’s dividend stood at $500 million in 2023-24.
France’s tax office said it could not comment for this story given the negotiations are ongoing, while the finance ministry did not respond to Reuters’ queries. India’s foreign and finance ministries also did not respond. Capgemini and Danone declined to comment while the other French companies did not respond to Reuters’ queries.
Currently, India can impose taxes on any French entity’s share sale, but only when it holds more than 10% of an Indian company. The new proposed treaty will remove that threshold.
The new treaty “will provide for full source-based taxation rights in respect of capital gains on equity shares (in India),” said the Indian documents.
France-based foreign portfolio investors (FPIs) own $21 billion worth of shares in Indian companies as of November 2025, a third higher than levels in 2024, Indian share depository data shows.
And more than 40 French companies hold stakes of under 10% in Indian entities, according to an analysis by Indian market intelligence platform Tracxn.
“This will impact French FPIs in India and also French companies holding minority interest in Indian companies. These investments were not subject to tax under the current treaty,” said Riaz Thingna, a partner at Grant Thornton Bharat LLP.
One official familiar with the deliberations told Reuters on condition of anonymity that Indian and French officials have agreed the terms of the new treaty, which will likely be signed in the coming weeks. In New Delhi, the deal is subject to final approval by Prime Minister Narendra Modi’s cabinet, according to the documents. Reuters is the first to report the planned changes to India-France treaty.
India has also agreed to France’s demand to limit tax on fees for technical services to cases where a French provider transfers technical know-how, removing most routine consultancy and support services from the scope of India’s tax. “This can help French companies that render services like design consultancy, cybersecurity and market research,” Thingna said.
Differences over how to interpret the so-called most-favoured nation, or MFN, clause were among the main reasons for the renegotiation, the official said. If a country has an MFN clause with India under a signed treaty, it typically starts claiming lower tax rates if New Delhi strikes more favourable tax terms later with another OECD nation. But a landmark Indian Supreme Court decision in late 2023 said countries can’t automatically start doing so, triggering concerns in France.
“This decision led to a sharp deterioration in the legal and economic security of French companies in India. The potential additional tax cost was estimated at 10 billion euros for existing contracts alone,” said the official.
India and France have reached a decision to delete the MFN clause from their treaty which had historically benefitted only France, according to Indian government documents. That was to put an end to disagreements related to its interpretation that have led to “tax uncertainty and protracted litigation,” said one document. Switzerland in January also suspended its application of the MFN clause in its India treaty citing the Supreme Court ruling.
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While rates initially jumped in early January, weak underlying demand and the potential return of vessels to the Suez Canal are creating a volatile environment for shippers, it noted.
Carriers pushed through general rate increases (GRIs) in early January this year, briefly lifting China-to-US West Coast rates above $3,000 per forty-foot equivalent unit (FEU). However, these hikes were largely unsustainable due to weak volumes, with rates quickly correcting to the $1,800-$2,200 range by mid-month, the logistics and supply chain market research firm said in an insights brief.
Asia’s ocean freight market is navigating short-term seasonal surges and long-term structural overcapacity, Ti said.
Asia’s air freight market is seeing a significant ‘post-peak’ correction following a record-breaking end to 2025.
Warehousing capacity in the Asia-Pacific is under severe strain in late January as manufacturing slows and labour shortages emerge ahead of the Lunar New Year.
Seasonal demand ahead of the Lunar New Year (starting mid-February 2026) has pushed North Europe rates to roughly $2,700 per FEU as of mid-January. This is a significant recovery from the October 2025 lows of $1,300 per FEU.
Despite a peak ahead of the holiday, Intra-Asia rates have begun to ‘cool’ in mid-January, settling at an average of $661 per 40-feet container as new services and capacity entered the market.
The Asian air freight market is witnessing a significant ‘post-peak’ correction following a record-breaking end to 2025. While rates have dropped sharply from their December highs, demand remains resilient in key high-tech sectors, and a ‘mini-peak’ is expected in late January ahead of the Lunar New Year.
Spot rates from major hubs like Hong Kong and Shanghai fell significantly in early January as year-end peak season demand evaporated.
Despite the rate correction, global air cargo tonnages jumped by 26 per cent in the first full week of January 2026 compared to the end-of-year slump, with the Asia-Pacific region seeing an 8 per cent year-on-year (YoY) increase in chargeable weight.
Volumes from Southeast Asia to the United States rose by 10 per cent YoY in early January, driven by importers continuing to diversify sourcing away from China.
Warehousing capacity in the Asia-Pacific is under severe strain in late January as manufacturing slows and labour shortages emerge ahead of the Lunar New Year.
India closed 2025 with 36.9 million sq ft of warehouse leasing (16-per cent YoY growth), a trend continuing into early 2026 with high demand in Delhi National Capital Region and Chennai.
After a period of oversupply, development pipelines are expected to drop by a third by 2027, making 2026 a critical ‘inflection point’ for occupiers to secure quality space before terms tighten again.
Fibre2Fashion (DS)
The goal, however, is challenging due to external pressures, including stricter technical barriers, reciprocal tariffs on goods exported to the United States, and the European Union’s Carbon Border Adjustment Mechanism (CBAM) for selected industrial products.
Therefore, major export industries in the country have started restructuring and adjusting strategies early in the year to seize market opportunities.
Following a record export value of $475 billion achieved in 2025—up by 17 per cent YoY—Vietnam aims at adding nearly $38 billion to the figure in 2026.
Major export industries in the country have begun restructuring and adjusting strategies early in the year to seize market opportunities.
The textile and garment sector, which earned $46 billion in 2025, has set a target of $50 billion in exports in 2026.
The textile and garment sector, which earned $46 billion in 2025, has set a target of $50 billion in exports in 2026.
The sector is focusing on strengthening domestic supply chains, raising localisation rates and making more effective use of free trade agreements (FTAs), Vu Duc Giang, chairman of the Vietnam Textile and Apparel Association (VITAS), was cited as saying by a domestic media outlet.
Exports may grow by 15-16 per cent this year, driven by market expansion and a shift towards higher-value products, according to MB Securities’ Vietnam Outlook 2026 report.
Fibre2Fashion (DS)
The data showed that the decline was driven mainly by weaker domestic exports, with goods produced in the Netherlands down 8 per cent YoY. In contrast, re-exports to the US rose 3.9 per cent during the period. Exports to the US have fallen every month on a YoY basis since July, CBS said in a press release.
Trade flows were influenced by uncertainty around US import tariffs. In the first half of 2025, trade between the two countries continued to grow, possibly as companies advanced shipments ahead of announced tariff measures.
Goods exports from the Netherlands to the United States fell 4.7 per cent YoY to €27.5 billion (~$33 billion) in the first ten months of 2025, driven by an 8 per cent drop in domestic exports, according to CBS.
Re-exports rose 3.9 per cent, while tariff uncertainty weighed on trade.
Imports from the US increased 1.9 per cent to €48.1 billion (~$57.7 billion).
Meanwhile, imports from the United States rose 1.9 per cent YoY to €48.1 billion (~$57.7 billion) in the first ten months of 2025.
Fibre2Fashion News Desk (SG)
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