{"query":"What is the India–Chile treaty withholding rate on royalties and fees for techni","matches":[{"id":"auto_wht_chile","question":"What is the India–Chile treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 10% of the gross amount — Article 12, India–Chile DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12A. Gate: the treaty rate applies only through s.393(2) Sl. No. 17 → s.2(90)(c) with the s.159(8) TRC + Form 10F gate met; domestic comparator 20% + surcharge/cess (s.207(2)). Notes: standalone-FTS-article-12A (UN Model Art 12A pattern — rare in the Indian network, shared with e.g. India–Colombia-era drafts; NOT the usual combined 'Royalties and FTS' Art 12); no-make-available (plain managerial/technical/consultancy definition); equipment-royalty-included-in-definition-at-same-10-rate (no split); recent-treaty (signed 2020, in force Oct 2022, effective India from FY 2023-24 — pre-2023-24 payments fall back to domestic law); no-MFN-clause; BEPS-native: PPT + simplified LOB built into treaty text; Chile-clause in Protocol preserves Chile's Impuesto Adicional on distributions (affects dividends, not royalty/FTS).","pinpoint":"Article 12, India–Chile DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Chile"}],"engine":"deterministic","llm_in_path":false}