{"query":"What is the India–Iceland treaty withholding rate on royalties and fees for tech","matches":[{"id":"auto_wht_iceland","question":"What is the India–Iceland 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–Iceland 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 Article 12 with one combined 10% cap; no-make-available: wide FTS definition (managerial/technical/consultancy incl. provision of personnel) with no make-available filter; equipment-royalty-in-definition-same-rate: ICS-equipment limb is inside the royalty definition at the same 10%, not a separate rate; protocol-LOB-anti-abuse-on-art-12: Protocol para III denies Art 12 benefits to special-tax-regime corporations with 25%+ non-resident ownership; source-rule-extension: Art 12(5)(b) deems royalties/FTS to arise where the right is used or services performed even when 5(a) does not allocate source — broader than OECD model.","pinpoint":"Article 12 (combined 'Royalties and fees for technical services'), India–Iceland DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Iceland"}],"engine":"deterministic","llm_in_path":false}