International Tax update for Germany, India and France

At a glance

Germany: Government approves draft Annual Tax Act 2026.

India: New Taxation and Other Laws (Amendment) 2026.

France: FASTER Directive – France prepares for new EU framework on WHT relief by 2030.

A closer look

Germany: Government approves draft Annual Tax Act 2026

The German government has approved the draft Annual Tax Act 2026, which includes a number of targeted amendments of existing rules and notably introduces some changes relating to withholding tax (“WHT”) procedures.

In particular, the draft Annual Tax Act 2026 seeks to simplify royalty WHT relief in cases where there is no treaty clearance procedure with the federal tax office, by increasing the annual maximum amount for qualifying royalites from EUR 10,000 to EUR 100,000.

Additionally, for shares held in collective custody (“girosammelverwahrte Anteile”), advance treaty clearance for dividend WHT would no longer be available. Instead, a reduced or zero percent dividend WHT must be claimed via a refund application with the German federal tax office.

While the draft bill is not yet enacted, these amendments are intended to apply to payments made after 31 December 2026. The draft bill will now proceed through the parliamentary legislative process.

Please read more here for details.

India Taxation and Other Laws (Amendment) Bill, 2026 passed by Lok Sabha

The Taxation and Other Laws (Amendment) Bill, 2026 (“TOLA 2026”), which includes a number of measures intended to promote foreign investment into India, was passed on 6 August 2026.

The Bill, once enacted, will, inter alia, amend the Income-tax Act, 2025 (“ITA 2025”) and the Finance Act, 2026 by rationalizing various provisions, providing legislative effect to measures previously introduced under the Income-tax (Amendment) Ordinance, 2026, and simplifying the tax framework applicable to foreign investors. Upon enactment, these amendments will be deemed effective from 1 April 2026.

Some of the notable proposed amendments of relevance for foreign investors include:

• Significant relaxation of the conditions governing eligible investment funds and eligible fund managers under the fund manager safe harbor regime, including the removal of several investor-level and investment-related requirements for qualifying funds;
• Formal recognition of the exemption for interest and capital gains earned by Foreign Institutional Investors (“FIIs”) and the Bank for International Settlements (“BIS”) in respect of income earned from Indian Government securities, and
• Expansion of the dividend exemption available in respect of specific income received by eligible business trusts and their unit holders so that the exemption would apply irrespective of whether the underlying special purpose vehicle (“SPV”) is subject to the old or new corporate tax regime.

France: FASTER directive - Key developments and practical considerations

Please find here an article detailing how France is preparing for the FASTER Directive (i.e. Council Directive (EU) 2025/50), a directive that introduces a common EU framework for withholding tax relief on cross-border dividend and interest payments, set to take effect from 1 January 2030. The article considers how the regime will operate and the practical considerations that investors should be bearing in mind as the 2030 implementation date approaches.