{"query":"What is the India–Croatia treaty withholding rate on royalties and fees for tech","matches":[{"id":"auto_wht_croatia","question":"What is the India–Croatia treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 10% of the gross amount — Article 12 (combined 'Royalties and Fees for Technical Services'), India–Croatia DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12 (same article as royalties). 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: fts-inside-royalty-article: royalties and FTS share a single combined Article 12 with one 10% rate; equipment-royalty-in-definition-no-separate-rate: ICS-equipment limb inside royalty definition at the same 10%; protocol-lob-clause: >50% non-resident ownership denies relief on dividends/interest/royalties/capital-gains — FTS is conspicuously absent from the denial list; no-make-available-and-no-mfn-route: 10% gross applies to plain managerial/technical/consultancy services with no restriction.","pinpoint":"Article 12 (combined 'Royalties and Fees for Technical Services'), India–Croatia DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Croatia"}],"engine":"deterministic","llm_in_path":false}