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India, France seal treaty revamp giving Paris dividend relief, Delhi tax rights

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India, France seal treaty revamp giving Paris dividend relief, Delhi tax rights


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Reuters

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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.

Bollywood celebrity Alia Bhatt for L’Oreal, a company which could be affected by the new treaty – ​L’Oréal Paris

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. 

© Thomson Reuters 2025 All rights reserved.



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Spain’s Inditex sees steady 9M 2025 growth & stronger Q3 momentum

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Spain’s Inditex sees steady 9M 2025 growth & stronger Q3 momentum



Spanish multinational clothing company, Inditex has delivered a strong operating performance in the first nine months of 2025 (9M 2025). Sales for the period rose 2.7 per cent to €28.2 billion (~$32.8 billion), or 6.2 per cent in constant currency, with both stores and online performing well. Gross profit increased 3.2 per cent to €16.8 billion, lifting gross margin to 59.7 per cent.

Inditex has posted strong 9M 2025 results, with sales up 2.7 per cent to €28.2 billion (~$32.8 billion) and gross margin at 59.7 per cent.
Profitability improved, with EBITDA at €8.3 billion (~$9.6 billion) and net income at €4.6 billion (~$5.3 billion).
Q3 saw sharper growth, early Q4 sales rose 10.6 per cent, and expansion plus new tech, including soft tags, continue to strengthen the business.

Operating expenses grew just 2.4 per cent, 29 basis points below sales growth. EBITDA reached €8.3 billion (~$9.6 billion), up 4.2 per cent, while EBIT rose 4.8 per cent to €5.9 billion. Net income grew 3.9 per cent to €4.6 billion (~$5.3 billion).

The Group said its fully integrated model, diversified footprint and agile sourcing approach remained key to execution. Inditex opened stores in 39 markets during the period, operating a total of 5,527 sites at the end of October. Inventory was 4.9 per cent higher year on year, which the company described as ‘high quality’.

In the third quarter (Q3) of 2025, momentum strengthened further. Sales advanced 4.9 per cent to €9.8 billion, or 8.4 per cent in constant currency. Gross profit increased 6.2 per cent to €6.1 billion, with gross margin expanding to 62.2 per cent, the group said in a financial release.

EBITDA rose 8.9 per cent to €3.2 billion, while EBIT climbed 11.2 per cent to €2.4 billion. Net income for the quarter increased 9 per cent to €1.8 billion. The Group ended the period with €11.3 billion in net cash.

Early fourth-quarter trading has been strong. Between November 1 and December 1, 2025, store and online sales in constant currency grew 10.6 per cent versus the same period in 2024.

Looking ahead, Inditex said its priority is to keep improving its fashion offer, strengthen customer experience and progress on sustainability. It highlighted the benefits of its flexible, proximity-based sourcing model and its diversified global presence across 214 markets. Gross margin for 2025 is expected to remain stable within a band of +/-50 basis points, while currency movements are forecast to have a -4 per cent impact on sales.

Investment plans remain substantial. Ordinary capital expenditure is estimated at €1.8 billion for the year, complemented by a two-year, €900-million-per-year logistics expansion programme for 2024–25. The Zaragoza II distribution centre is now operational, and Zara’s new 200,000m² building in Arteixo was inaugurated in October.

“Zara has launched in new locations for example in Las Vegas Forum Shops at Caesars Palace. This week, we will open a new store in, Charlotte North Carolina, as well as a Zara Man standalone store in Palazzo Verospi, Rome. Additionally, we have made important relocations and refurbishments in Osaka Shinsaibashi, Austin The Domain, Maastricht Grote Straat and Barcelona Diagonal. We continue introducing the new soft-tag technology in our stores with a significant improvement in customer experience. The new system is now fully operational in Zara and is being rolled out in Bershka and Pull&Bear,” the release added.

Fibre2Fashion News Desk (HU)



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UK fashion sector posts QoQ revenue lift as market recovery builds

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UK fashion sector posts QoQ revenue lift as market recovery builds



Average sales revenue for UK clothing and fashion manufacturers reached £500,517 (~$670,693) in Q3 2025, marking a 4.3 per cent rise quarter-on-quarter (QoQ), according to the latest figures from inventory management platform Unleashed. While this rebound signals improved trading conditions, sales remained 4.4 per cent lower year-on-year (YoY), reflecting ongoing softer demand and reduced purchasing activity.

Despite improved sales performance, profitability slipped slightly, with gross margin percentage (GMP) falling to 60.4 per cent—down 2.5 percentage points (pp) QoQ and 1.7 points YoY. The decline reflects reduced order volumes and ongoing pricing pressures across the supply chain, even as firms increased sales output.

The operational metrics revealed a decisive pivot towards efficiency. Lead times improved significantly, dropping from 32 days to 22 days QoQ—a reduction of 31 per cent. Meanwhile, purchase orders declined sharply by 56 per cent, while stock on hand fell by 33.5 per cent, suggesting firms are prioritising leaner inventory management to minimise risk and optimise working capital.

UK fashion manufacturers saw average Q3 2025 sales rise 4.3 per cent QoQ to £500,517 (~$670,693), though still 4.4 per cent lower YoY, according to Unleashed.
Gross margin percentage slipped to 60.4 per cent as firms reduced purchase orders and stock.
The shift towards leaner inventory reflects cost pressures and soft demand, with operational efficiency expected to be key heading into 2026.

Joe Llewellyn, GM of ERP Small Business at The Access Group, parent company of Unleashed, said the shift was deliberate and strategic.

“The last quarter was characterised by a determined push towards efficiency,” he noted. “Our data shows firms have moved from cautious ‘just in case’ stock building in Q2 to a leaner just-in-time strategy, cutting stock and purchasing activity to protect margins and cash flow.”

Llewellyn added that with the UK manufacturing PMI remaining in contraction through the period, firms responded pre-emptively to weaker demand signals and sustained cost pressures.

“Operational excellence will be increasingly important going into 2026,” he added. “Manufacturers will need real-time visibility of landed costs, improved forecasting, and the ability to convert excess stock into cash. Doing more with less is now the reality.”

The broader manufacturing landscape reflected similar patterns. Firms recorded a 12.9 per cent QoQ rise in sales and a 1.3 percentage point uplift in Gross Margin Percentage (GMP) to 39.66 per cent. Purchase orders fell by 30 per cent, stock on hand dropped 27.2 per cent, and lead times shortened by eight days, the report added.

With global demand stabilising but cost pressures likely to persist into next year, UK fashion manufacturers are expected to continue prioritising automation, inventory precision, and digital forecasting tools to remain resilient.

The figures signal a cautiously optimistic outlook: the industry appears better positioned than earlier in 2025, but sustained recovery will depend heavily on operational discipline, demand visibility, and navigating a still-volatile cost environment.

The report, based on data from more than 600 small and mid-sized firms, suggests manufacturers are entering 2026 on firmer footing as streamlined operations and improving sales help stabilise margins.

Fibre2Fashion News Desk (SG)



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EU introduces €3 levy on small parcels from China

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EU introduces €3 levy on small parcels from China


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December 12, 2025

The principle has been agreed, but the practical details have yet to be worked out. From July 1, a three-euro tax will be applied to small non-EU parcels entering the European Union, marking the end of the tax exemption for parcels under 150 euros, in a bid to rein in Shein and Temu.

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Some 4.6 billion consignments worth less than 150 euros entered the European market in 2024, at a rate of more than 145 every second. Of this total, 91% came from China. A month ago, EU finance ministers approved scrapping, from next year, the duty-free status enjoyed by these parcels.

While this measure is intended to apply to parcels from all countries outside the EU, it is primarily aimed at stemming the flood of low-priced Chinese products into Europe, which often fail to comply with European standards, and are purchased on Asian platforms such as Shein, Temu, or AliExpress.

This influx of imported parcels with no customs duty has increasingly been denounced by European producers and retailers as a form of unfair competition.

Moreover, the volume of parcels arriving at European airports and ports is so great that customs officers are frequently unable to check whether they comply. In these circumstances, it is difficult to intercept dangerous or counterfeit products before they reach consumers.

“Four years ago, there were one billion parcels arriving from China. Today, it’s more than four billion,” noted French Economy Minister Roland Lescure. “Today, these parcels represent unfair competition for city-centre businesses which pay taxes, so it’s essential to act and act fast, otherwise we will act too late,” he told AFP.

A Herculean task

France, in the midst of a stand-off with Chinese e-commerce giant Shein following the scandal over the sale of childlike sex dolls and Category A weapons, has led this battle in Brussels to scrap the exemption from customs duties on these low-value shipments.

The measure had in fact already been planned as part of the reform of the Customs Union (the European customs system), but it is not due to apply until 2028. In November, the 27 member states agreed to implement it “as soon as possible” in 2026.

But that means finding a “simple and temporary” solution for taxing these billions of parcels, until the customs data platform provided for in the reform, which should greatly facilitate the collection of customs duties, becomes operational.

According to some members of parliament, applying the usual customs duties to small parcels from 2026 onwards- with rates varying according to product category or sub-category and the country of import- would be a Herculean task, risking clogging up already overburdened customs services even further.

Roland Lescure made it clear on Thursday that he would defend “a flat-rate tax, because we want the measures taken in Europe to have an impact,” rather than “proportional taxation,” which he believes would not be a sufficient deterrent.

A first step

However, setting up a transitional system “is not easy, because we have to do it with our existing resources,” said a European diplomat, who on Thursday declined to give an exact date for the entry into force of the provisional system.

The taxation of small parcels is just the first step in the EU’s offensive against the avalanche of Chinese products entering its territory: from November 2026, it is due to be accompanied by the introduction of handling fees on these same parcels valued at less than 150 euros. In May, Brussels proposed setting them at two euros per parcel.

This sum will help finance the development of controls and, according to the EU, together with the collection of customs duties, will help level the playing field between European products and competition “made in China.”

FashionNetwork.com with AFP

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