According to the updated provisions of the India–France DTAC protocol, what dividend tax rate applies to shareholders holding at least 10% of the company’s capital?

Under the revised provisions of the India–France Double Taxation Avoidance Convention, the dividend taxation structure has been modified. Shareholders who hold at least 10% of the company’s capital will now be subject to a dividend tax rate of 5%. Earlier, the DTAC applied a single tax rate of 10% on dividend income. The new structure introduces two tiers: 5% for substantial shareholders holding at least 10% of capital, and 15% for all other shareholders. This revision provides clearer taxation rules for cross-border investments between India and France.