Necessary for implementing the aforesaid Convention between India and France

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....e said ^1[Convention;] And whereas the Central ^2[Government, in exercise] of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1969) and section 44A of the Wealth-tax Act, 1957 (27 of 1957), had directed that all the provisions of the said Convention annexed to the notification of the Government of India in the Ministry of Finance (Department of Revenue) (Foreign Tax^3[Division]) No. G.S.R. 681(E), dated 7th September, 1994, shall be given ^4[effect to in] in the Union of India. And whereas paragraph 7 of the Protocol dated 29th September, 1992, to the aforesaid Convention provides that if after 1st day of September, 1989, under any ^5[Convention....

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.... hereby directs that the following modifications shall be made in the Convention notified by the said notification which are necessary for implementing the aforesaid Convention between India and France, namely :-- I. With effect from 1st April, 1997, for the existing paragraph 2 of article 11 relating to "Dividends", the following paragraph shall be ^8[read:] "2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the dividends, the tax so charged shall not exceed 10 per cent. of the gross amount of the ^9[dividends."] II. With effect from 1st April, 1995, ....

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....royalties, fees and payments] may also be taxed in the Contracting State in which they arise and according to the laws of that ^18[Contracting State,] but if the recipient is the beneficial owner of these categories of income, the tax so charged shall not ^19[exceed:] (a) in the case of royalties and fees 20 per cent. of the gross amount of such royalties or fees ; and (b) in the case of payments referred to in paragraph 5 of this article, 10 per cent. of the gross amount of such ^20[payments."] V. With effect from 1st April, 1997, for paragraph 2 of article 13 relating to "Royalties and fees for technical services and payments for the use of equipment", referred to in paragraph IV above, the following paragraph shall b....