MoneyControl: Proposed tweaks to India–France tax treaty may further reduce attractiveness of P-notes issued from that country

My take on the recent revision in the India – France DTAA, as quoted in MoneyControl. Clearly, an increased withholding tax rate for shareholders with less than 10% marks a distinction between portfolio investors and strategic investors. Coupled with the amendment that capital gains tax also would be fully sourced based irrespective of 10% holding (which was there earlier), the post tax IRR from French portfolio investors would consequently be lower.

Link: https://www.moneycontrol.com/news/business/proposed-tweaks-to-india-france-tax-treaty-may-further-reduce-attractiveness-of-p-notes-issued-from-that-country-13725642.html