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 increase was driven primarily by higher reinvested earnings and intra-company loans, indicating continued engagement by existing investors with Bangladesh.
Reinvested earnings rose by 318.25 per cent, from $103.79 million in 2024 to $434.10 million in 2025, while intra-company loans increased by 25.68 per cent, from $621.96 million to $781.68 million.
Bangladesh’s net FDI inflows increased by 39.36 per cent last year to $1,770.42 million compared with $1,270.39 million in 2024, the Bangladesh Bank said.
The increase was driven primarily by higher reinvested earnings and intra-company loans.
Reinvested earnings rose by 318.25 per cent, from $103.79 million in 2024 to $434.10 million in 2025, while intra-company loans rose by 25.68 per cent.
Equity capital remained broadly stable, rising by 1.84 per cent, from $544.64 million to $554.64 million in 2025, a release from Bangladesh Investment Development Authority said.
Greenfield project announcements declined by 16 per cent in 2025.
Fibre2Fashion News Desk (DS)
The company’s adjusted EBITDA, excluding Employee Stock Option Plan (ESOP) expenses, rose around 14 per cent YoY to ₹468 crore, while EBITDA margin improved by 20 basis points to around 9.3 per cent. Excluding the reciprocal tariff impact of around ₹36 crore and incremental losses of around ₹13 crore in Bihar and Guatemala, adjusted EBITDA margin stood at around 10.3 per cent.
Pallab Banerjee, managing director, Pearl Global Industries, said: “FY26 marked the company’s second consecutive year of double-digit growth and improved profitability. This performance further solidifies the position of Pearl Global’s diversified operating model and disciplined execution across geographies.”
Pearl Global Industries has reported its highest-ever FY26 revenue of ₹5,025 crore (~$523.93 million), up 11.5 per cent YoY, driven by volume growth and value-added products.
PAT rose 17 per cent to ₹270 crore (~$28.15 million), while Q4 revenue hit ₹1,314 crore (~$137 million).
The company shipped 78.1 million pieces.
Its net worth stands at ₹1,438 crore (~$149.93 million).
He said that geopolitical shifts and Gulf conflicts could lead to energy cost escalation, affecting raw material and logistics costs. However, the company remains prepared to manage these headwinds, supported by its diversified manufacturing base, strong order book, and broad market presence.
The profit after tax (PAT) increased 17 per cent YoY to ₹270 crore (~$28.15 million), the company said in a press release.
On a standalone basis, FY26 revenue stood at ₹1,081 crore, while adjusted EBITDA was ₹67 crore, with EBITDA margin improving by 60 basis points to 6.2 per cent, mainly due to cost restructuring. Standalone PAT rose to ₹69 crore from ₹55 crore in the previous year.
The company’s net worth stood at ₹1,438 crore (~$149.93 million) as of March 31, 2026, compared with ₹1,146 crore a year earlier.
“In FY26, Group delivered another year of resilient performance against a complex geopolitical backdrop. Group achieved, among others, two major milestones this year: revenue crossed INR 5,000 crore mark and installed capacity surpassed 100 million pieces per annum,” said Pulkit Seth, vice-chairman and non-executive director, PGIL.
Seth added that the global apparel industry faced tariff-related disruptions during FY26, with the company’s India operations impacted by tariffs and penal duties imposed by the US. However, he added that Pearl Global leveraged its diversified, multi-country manufacturing presence to mitigate these challenges and deliver double-digit growth.
For the fourth quarter (Q4) of FY26, PGIL posted its highest-ever quarterly revenue of ₹1,314 crore (~$137 million), up 6.9 per cent YoY. Adjusted EBITDA rose 13.7 per cent to ₹135 crore, with margin at 10.3 per cent, the highest EBITDA margin recorded by the company in any quarter. PAT for the quarter stood at ₹81 crore, up 24.6 per cent YoY, PGIL said in a press release.
Standalone revenue during the quarter stood at ₹304 crore, adjusted EBITDA at ₹24 crore, and PAT at ₹14 crore.
PGIL shipped its highest-ever volumes in Q4 FY26 and FY26, at 22 million pieces and 78.1 million pieces respectively. Its annual installed capacity crossed 100 million pieces, reaching around 101 million pieces.
The ongoing capex in Bangladesh is expected to be completed by the first half of FY27 and will add around 6-7 million pieces of capacity during the year.
Fibre2Fashion News Desk (SG)
PTA prices recorded notable declines across key Asian benchmarks, tracking crude oil weakness rooted in evolving geopolitical signals. The correction was broad-based, spanning China, Southeast Asia, and South Korea, while India**;s CIF price held steady reflecting the lag in import contract structures and limited spot availability in the domestic market on the day.
The *** per cent Polyester Yarn market witnessed a slightly negative trend during the assessed period, with mild price corrections observed across both yarn grades in the Asia Free on Board (FOB) China market. Prices for **s (*** per cent polyester yarn) declined from around $*.***/kg to nearly $*.***/kg, registering a decrease of approximately *.** per cent.
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