Article 2 - Interpretation of Terms - France - Convention to Implement Tax Treaty related Measures to Prevent Base Erosion and Profit Shifting

Article 2 Interpretation of Terms Notification - Agreements Covered by the Convention Pursuant to Article 2(1)(a)(ii) of the Convention, India wishes the following agreement(s) to be covered by the Convention: No Title Other Contracting Jurisdiction Original/ Amending Instrument Date of Signature Date of Entry into Force 1 Agreement between the Government of the Republic of India and The Republic of Albania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Albania Original 08.07.2013 04.12.2013 2 Convention between the Government of the Republic of India and The Government of the Republic of Armenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect of Taxes on Income. Armenia Original 31.10.2003 09.09.2004 1 Amending Instrument (a) 27.01.2016 14.06.2017 3 Agreement between the Government of the Republic of India and the Government of Australia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Australia Original 25.07.1991 30.12.1991 Amending Instrument(a) 16.12.2011 02.04.2013 4 Convention between the Government of the Republic of India and The Government of the Republic of Austria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect of Taxes on Income. Austria Original 08.11.1999 05.09.2001 Amending Instrument (a) 06.02.2017 N/A 5 Convention between the Government of the Republic of India and the Government of the People's Republic of Bangladesh for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Bangladesh Original 27-08-1991 27-05-1992 Amending Instrument (a) 16-02-2013 13-06-2013 6 Agreement between the Government of the Republic of India and The Republic of Belarus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property (Capital). Belarus (Part of USSR) Original 27.09.1997 17.07.1998 Amending Instrument (a) 03.06.2015 19.11.2015 7 Agreement between the Government of the Republic of India and the Government of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Belgium Original 26.04.1993 01.10.1997 Amending Instrument (a) 09.03.2017 N/A 8 Agreement between the Government of the Republic of India and the Royal Government of Bhutan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Bhutan Original 04-03-2013 17-07-2014 9 Convention between India and Botswana for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect of Taxes on income Botswana Original 08-12-2006 30-01-2008 10 Convention between the government of the Republic of India and the government of the Federation Republic of Brazil for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Brazil Original 26.04.1988 11.03.1992 Amending Instrument (a) 15.10.2013 06.08.2017 11 Convention between the Government of the Republic of India and the Government of the Republic of Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Bulgaria Original 26.05.1994 23.06.1995 12 Agreement between the Government of the Republic of India and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Canada Original 11.01.1996 06.05.1997 13 Convention between the government of the Republic of India and the government of the Republic of Colombia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Colombia Original 13.05.2011 07.07.2014 14 Agreement between The Government of the Republic of India and The Government of the Republic of Croatia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect of Taxes on Income. Croatia Original 12.02.2014 06.02.2015 2 15 Agreement and Protocol between the Government of the Republic of India and the Government of the Republic of Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Cyprus Original 18.11.2016 14.12.2016 16 Convention between the Government of the Republic of India and the Government of the Czech Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Czech Republic Original 01.10.1998 27.09.1999 17 Convention between the Republic of India and the Kingdom of Denmark for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital. Denmark Original 08.03.1989 13.06.1989 Amending Instrument (a) 10.10.2013 01.02.2015 18 Agreement between India and Egypt for the Avoidance of Double taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Egypt Original 20-02-1969 30-09-1969 19 Agreement between the Republic of India and the Republic of Estonia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Estonia Original 19.09.2011 20.06.2012 20 Convention Between India and Ethiopia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains. Ethiopia Original 25-05-2011 15-10-2012 21 Agreement between the Government of the Republic of India and the Government of Fiji for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Fiji Original 30.01.2014 15.05.2014 22 Agreement and Protocol between the Republic of India and the Republic of Finland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Finland Original 15.01.2010 19.04.2010 23 Convention between the Government of 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 on Income and on Capital. France Original 29.09.1992 01.08.1994 24 Agreement between the Government of the Republic of India and the Government of the Georgia for the Avoidance of Double Taxation of Income and on Capital. Georgia Original 24.08.2011 08.12.2011 25 Agreement between the Republic of India and the Federal Republic of Germany for the Avoidance of Double Taxation of Income and on Capital. Germany Original 19.06.1995 26.10.1996 26 Agreement between the Government of India and the Government of Greece for the Avoidance of Double Taxation of Income. Greece Original 11.02.1965 17.03.1967 27 Agreement between the Government of the Republic of India and the Government of the Hong Kong Special Administrative Region of the People s Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Hong Kong Original 19.03.2018 30.11.2018 28 Agreement between the Government of India and the Government of Hungary for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income Hungary Original 03.11.2003 04.03.2005 29 Agreement between the Republic of India and the Government of Iceland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Iceland Original 23.11.2007 21.12.2007 30 Agreement between the Government of the Republic of India and the Government of the Republic of Indonesia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Indonesia Original 27-07-2012 05-02-2016 31 Convention between the Government of the Republic of India and the Government of Ireland for the Avoidance of Double Taxation and for the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains. Ireland Original 06.11.2000 26.12.2001 3 32 Convention between the Republic of India and the State of Israel for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income and on capital Israel Original 29-01-1996 15-05-1996 Amending Instrument (a) 14-10-2015 19-12-2016 33 Convention between the Government of Republic of India and the Government of the Republic of Italy for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income Italy Original 19.02.1993 23.11.1995 34 Convention between the government of the Republic of India and the government of Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Japan Original 07.03.1989 29.12.1989 Amending Instrument (a) 24.02.2006 28.06.2006 Amending Instrument (b) 11.12.2015 29.10.2016 35 Convention between the Government of the Republic of India and the Government of the Hashemite Kingdom of Jordan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Jordan Original 20-04-1999 16-10-1999 36 Convention between the Government of the Republic of India and the Government of the Republic of Kazakstan for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income and on capital Kazakstan Original 09-12-1996 02-10-1997 Amending Instrument (a) 06-01-2017 12-03-2018 37 Agreement between India and Kenya for the Avoidance of Double taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Kenya Original 11-07-2016 30-08-2017 38 Agreement between the Government of the Republic of India and the Government of the Republic of Korea for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Korea Original 18-05-2015 12-09-2016 39 Agreement between the Government of the Republic of India and the Government of the State of Kuwait for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Kuwait Original 15-06-2006 17-10-2007 Amending Instrument (a) 15-01-2017 26-03-2018 40 Agreement between the Government of the Republic of India and the Government of the Kyrgyz Republic for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income Kyrgyz Republic Original 13-04-1999 10-01-2001 41 Agreement between the Government of the Republic of India and the Government of the Republic of Latvia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income Latvia Original 18.09.2013 28.12.2013 42 Convention Government of India and Libya for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income Libya Original 02-03-1981 01-07-1982 43 Agreement and the protocol between the Government of the Republic of India and the Government of the Republic of Lithuania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Lithuania Original 26.07.2011 10.07.2012 44 Agreement between the Government of Republic of India and the Government of the Grand Duchy of Luxembourg for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital. Luxembourg Original 02.06.2008 09.07.2009 45 Agreement between the Government of the Republic of India and the Government of the Republic of Macedonia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Macedonia Original 17.12.2013 12.09.2014 46 Agreement between the Government of the Republic of India and the Government of Malaysia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Malaysia Original 09-05-2012 26-12-2012 47 Agreement and the Protocol between the Government of the Republic of India and the Government of the Republic of Malta for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income Malta Original 08.04.2013 07.02.2014 48 Agreement between the Government of the Republic of India and the Government of Mauritius for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Mauritius Original 24.08.1982 06.12.1983 Amending Instrument (a) 10.05.2016 19.07.2016 49 Agreement and Protocol between the Government of the Republic of India and the Government of the United Mexican States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income Mexico Original 10.09.2007 01.02.2010 50 Agreement between the Government of the Republic of India and the Government of Mongolia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital Mongolia Original 22-02-1994 29-03-1996 51 Convention between the Republic Of India and the Government of the Council of Ministers of Serbia and Montenegro for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Montenegro Original 08.02.2006 23.09.2008 52 Convention between the Republic of India and the Kingdom of Morocco for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Morocco Original 30.10.1998 20.02.2000 Amending Instrument (a) 08.08.2013 N/A 53 Agreement between the Government of the Republic of India and the Government of the Republic of Mozambique for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Mozambique Original 30.09.2010 28.02.2011 54 Agreement between the Government of the Republic of India and the Government of the Union of Myanmar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Myanmar Original 02-04-2008 30-01-2009 55 Convention between the Government of the Republic of India and the Government of the Republic of Namibia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains Namibia Original 15.02.1997 22.01.1999 56 Agreement between the Government of the Republic of India and the Government of Nepal for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Nepal Original 27-11-2011 16-03-2012 57 Convention between the Government of Republic of India and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Netherlands Original 30.07.1988 21.01.1989 Amending Instrument (a) 10.05.2012 02.11.2012 58 Convention between the Republic of India and the Government of New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income New Zealand Original 17.10.1986 03.12.1986 Amending Instrument (a) 29.08.1996 09.01.1997 Amending Instrument (b) 21.06.1999 30.12.1999 4 Amending Instrument (c) 26.10.2016 07.09.2017 59 Agreement Between the Republic of India and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Norway Original 02.02.2011 20.12.2011 60 Agreement between the Republic of India and the Sultanate of Oman for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Oman Original 02-04-1997 03-06-1997 61 Convention between the Republic of India and the Republic of the Philippines for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Philippines Original 12-02-1990 21-03-1994 62 Agreement between the Government of Republic of India for the Government of Polish People s Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Poland Original 21.06.1989 26.10.1989 Amending Instrument (a) 29.01.2013 01.06.2014 63 Convention between the Government of Republic of India and the Government of the Portuguese Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Portugal Original 11.09.1998 30.04.2000 5 Amending Instrument (a) 24.06.2017 08.08.2018 64 Agreement between the Government of the Republic of India and the Government of the State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Qatar Original 07-04-1999 15-01-2000 65 Agreement between the Republic of India and Romania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Romania Original 08.03.2013 16.12.2013 66 Agreement between the Government of the Republic of India and the Government of the Russian Federation for the Avoidance of Double Taxation with respect to taxes on Income. Russia Original 25.03.1997 11.04.1998 67 Convention between the Government of the Republic of India and the Government of the Kingdom of Saudi Arabia for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income Saudi Arabia Original 25-01-2006 01-11-2006 68 Convention between the Republic Of India and the Government of the Council of Ministers of Serbia And Montenegro for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Serbia Original 08.02.2006 23.09.2008 69 Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Singapore Original 24-01-1994 27-05-1994 Amending Instrument (a) 29-06-2005 01-08-2005 Amending Instrument (b) 24-06-2011 01-09-2011 Amending Instrument (c) 30-12-2016 27/02/2017 70 Agreement between the Government of India and the Government of the Czechoslovak Socialist Republic for the Avoidance of Double taxation and the prevention of fiscal evasion with respect to taxes on income. Slovak Republic Original 27.01.1986 13.03.1987 71 Convention between the Republic Of India and the Republic of Slovenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Slovenia Original 13.01.2003 17.02.2005 Amending Instrument (a) 17.5.2016 21.12.2016 72 Agreement between the Government of the Republic of India and the Government of the Republic of South Africa for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income South Africa Original 04.12.1996 28.11.1997 Amending Instrument (a) 26.7.2013 26.11.2014 73 Convention between the Republic Of India and the Kingdom of Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Spain Original Amending Instrument (a) 08.02.1993 26.10.2012 12.01.1995 N/A 74 Agreement between the Government of the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Sri Lanka Original 22-01-2013 22-10-2013 75 Agreement between the Government of the Republic of India and the Government of the Republic of the Sudan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Sudan Original 22.10.2003 15.04.2004 76 Convention between the Republic of India and the Government of Kingdom of Sweden for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital. Sweden Original 24.06.1997 25.12.1997 Amending Instrument (a) 07.02.2013 16.08.2013 77 Agreement between the Government of India and Swiss Confederation for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Swiss Confederation Original 02.11.1994 29.12.1994 Amending Instrument (a) 16.02.2000 20.12.2000 Amending Instrument (b) 30.08.2010 07.10.2011 78 Agreement between the Government of the Republic of India and the Government of the Syrian Arab Republic for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income Syria Original 18-06-2008 10-11-2008 79 Agreement between the Government of the Republic of India and the Government of the Republic of Tajikistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Tajikistan Original 20-11-2008 10-04-2009 Amending Instrument (a) 17-12-2016 20-02-2018 80 Agreement between the Government of the Republic of India and the Government of the United Republic of Tanzania for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Tanzania Original 27.05.2011 12.12.2011 81 Agreement between the Government of the Republic of India and the Government of the Kingdom of Thailand for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Thailand Original 29-06-2015 13-10-2015 6 82 Convention between the Government of the Republic of India and the Government of Republic of Trinidad and Tobago for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Trinidad and Tobago Original 08.02.1999 13.10.1999 83 Agreement between the Government of Republic of India and the Republic of Turkey for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Turkey Original 31.01.1995 01.02.1997 7 84 Convention between the Government of Republic of India and the Government of Turkmenistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital Turkmenistan Original 25-02-1997 07-07-1997 85 Convention between the Government of the Republic of India and the Government of the Republic of Uganda for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income Uganda Original 30.04.2004 27.08.2004 86 Convention between the Government of the Republic of India and the Government of the Ukraine for the Avoidance of Double Taxation and the Prevention of fiscal Evasion with Respect to Taxes on Income and on Capital. Ukraine Original 07.04.1999 31.10.2001 87 An Agreement between the Government of the Republic of India and the Government of the United Arab Emirates for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital United Arab Emirates Original 29-04-1992 22-09-1993 Amending Instrument (a) 26-03-2007 03-10-2007 Amending Instrument (b) 16-04-2012 12-03-2013 88 Convention between the Government of Republic of India and the Government of United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. United Kingdom Original 25.01.1993 26.10.1993 8 Amending Instrument (a) 30.10.2012 27.12.2013 89 Convention between the government of the Republic of India and the government of the Oriental Republic of Uruguay for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Uruguay Original 08.09.2011 21.06.2013 90 Convention between the Government of the Republic of India and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of fiscal Evasion with Respect to Taxes on Income. USA Original 12.09.1989 18.12.1990 91 Agreement between the Government of the Republic of India and the Government of the Republic of Uzbekistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital Uzbekistan Original 29-07-1993 25-01-1994 Amending Instrument (a) 11-04-2012 20-07-2012 92 Agreement between the Republic of India and the Socialist Republic of Vietnam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Vietnam Original 07-09-1994 02-02-1995 Amending Instrument (a) 03-09-2016 21-02-2017 93 Convention between the Government of the Republic of India and the Government of Zambia for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income Zambia Original 05.06.1981 18.01.1984