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..... 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 on Income and on capital signed on 29th September, 1992 (the Convention ), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the India and French Republic on 7th June, 2017 (the MLI ). The document was prepared on the basis of the MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the French Republic submitted to the Depositary upon ratification on 26th September, 2018. These MLI positions are subject to modifications as .....

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..... taken effect. References : The authentic legal text of the MLI (in English) can be found on the MLI Depository (OECD) webpage at the following link: http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf The authentic legal texts of the Convention (in English) can be found at the following link: In India : https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx In France : https://www.impots.gouv.fr/portail/les-conventions-internationales The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the French Republic submitted to the Depositary upon ratification on 26th September, 2018 can be found on th .....

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..... xpiration of a period of six calendar months from 1 October 2019. CONVENTION 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 ON INCOME AND ON CAPITAL The Government of the Republic of India and Government of the French Republic, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital; The following paragraph 1 of Article 6 of the MLI is included in the preamble of this Convention: ARTICLE 6 OF THE MLI- PURPOSE OF A COVERED TAX AGREEMENT Intending to eliminate double taxation with respect to the taxes covered .....

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