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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The uncertainty has increased noticeably, with the ongoing conflict involving Iran weighing heavily on corporate confidence. The escalation has effectively stalled hopes of a near-term economic recovery, particularly as energy markets remain volatile, ifo said in a press release.
In the manufacturing sector, sentiment declined after showing improvement in recent months. The drop was driven largely by a significant deterioration in expectations, while firms also reported a less favourable view of their current business situation. Energy-intensive industries were particularly affected, underscoring the pressure from elevated input costs.
Germany’s business sentiment weakened in March, with the ifo business climate index falling to 86.4 from 88.4 amid rising uncertainty and the Iran conflict dampening recovery hopes.
Manufacturing saw a sharp drop in expectations, especially in energy-intensive sectors.
Trade sentiment also declined due to inflation concerns, although current conditions remained relatively stable across sectors.
The trade sector also registered a decline in sentiment, primarily due to a more pessimistic outlook. Concerns over rising inflation among German consumers have led to weaker expectations in both wholesale and retail segments, signalling subdued demand conditions ahead.
Despite the gloomier outlook, businesses in the trade sector reported a slightly improved assessment of their current situation. This suggests that while present activity remains relatively stable, confidence in future performance is deteriorating.
Fibre2Fashion News Desk (SG)
Operating gross profit surged 35.1 per cent to $886.0 million, while underlying earnings before interest and tax (EBIT) rose 10.5 per cent to $112.8 million. Underlying net profit after tax (NPAT) increased 21.7 per cent to $51.7 million, with statutory net profit after tax (NPAT) up 32.8 per cent to $40.3 million.
Myer has reported strong H1 FY26 results, with total sales rising 24.5 per cent to $2,279.5 million and NPAT up 21.7 per cent to $51.7 million.
Growth was supported by Apparel Brands integration and strategic investments.
Loyalty members reached 5.1 million.
Early H2 FY26 sales rose 1.7 per cent, though the company remains cautious amid macroeconomic pressures and weak discretionary demand.
The company maintained strong financial discipline, with cost of doing business at 27.9 per cent of total sales, within its FY26 target of around 29 per cent. Myer also reported a robust net cash position of $287 million, reflecting strong cash conversion and balance sheet flexibility, Myer said in a press release.
Myer’s ongoing transformation strategy continued to gain traction during the period, particularly through its customer engagement and brand expansion initiatives. The relaunched Myer one loyalty programme reached a record 5.1 million active members, supported by enhanced personalisation driven by AI-led data modelling.
The company also strengthened its product portfolio, introducing new exclusive brands and securing partnerships with global names such as Fenty Beauty, La Mer, Gap, and Topshop.
“Our H1 result reflects momentum across our business as we continue to implement the Myer Group Growth Strategy. Sales growth was achieved both in store and online, and our disciplined cost management allowed us to make targeted investments including in e-commerce, marketing, product, merchandise and supply chain to deliver on our plan,” said Olivia Wirth, executive chair at Myer.
“We achieved our biggest Black Friday on record for Myer Retail, and total sales for the group through the important trading months of December and January were in line with last year—a good outcome that demonstrates the resilience of the business,” added Wirth.
The integration of Myer Apparel Brands progressed steadily, with the company targeting at least $30 million in annualised synergies, alongside an additional $10 million from integrating sass & bide, Marcs, and David Lawrence.
Operationally, Myer continued to optimise its store network, closing 22 stores and opening 12 during the period, while advancing its omni-channel capabilities. The company is set to launch an expanded Myer Marketplace platform in May 2026.
Supply chain efficiency also improved, with 32 per cent of online orders fulfilled through third-party logistics and distribution centres, compared to 13 per cent a year earlier.
In the first seven weeks of the second half (H2), total sales grew 1.7 per cent YoY, with Myer Retail sales up 2.2 per cent, driven by strong performance in home and kids categories.
Despite the positive momentum, the company remains cautious amid macroeconomic uncertainty and pressure on discretionary spending.
“Given the current volatility in the wider macroeconomic environment and the ongoing pressures on discretionary spending, we are more focused than ever on delivering value for our customers,” added Wirth.
Fibre2Fashion News Desk (SG)
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