Agreement between the Government of the Republic of India and the Government of the French Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes - G.S.R. 681(E) - Income Tax Act, 1961
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Double taxation avoidance: allocates taxing rights between India and France and prescribes relief via tax credits and limited source withholding. Convention allocates taxing rights between India and France to avoid double taxation and prevent fiscal evasion, applying to residents and specified taxes, with definitions for residence and permanent establishment. It prescribes taxation rules for business profits (arm's length attribution to permanent establishments), immovable and movable property, dividends, interest, royalties, technical service fees, and capital gains; caps source withholding on certain passive and service payments, provides specified exemptions, and requires elimination of double taxation by deduction (India) or tax credit/exemption (France). Procedural safeguards include a mutual agreement procedure and exchange of information rules.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Double taxation avoidance: allocates taxing rights between India and France and prescribes relief via tax credits and limited source withholding.
Convention allocates taxing rights between India and France to avoid double taxation and prevent fiscal evasion, applying to residents and specified taxes, with definitions for residence and permanent establishment. It prescribes taxation rules for business profits (arm's length attribution to permanent establishments), immovable and movable property, dividends, interest, royalties, technical service fees, and capital gains; caps source withholding on certain passive and service payments, provides specified exemptions, and requires elimination of double taxation by deduction (India) or tax credit/exemption (France). Procedural safeguards include a mutual agreement procedure and exchange of information rules.
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