{"query":"What is the India–Indonesia treaty withholding rate on royalties and fees for te","matches":[{"id":"auto_wht_indonesia","question":"What is the India–Indonesia treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 10% of the gross amount — Article 12 (titled 'Royalties and Fees for Technical Services'), India–Indonesia DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12 (combined with royalties — no standalone FTS article). 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 (single combined Art 12, no standalone FTS article); treaty-renegotiated (1987 treaty wholly replaced effective 1 Apr 2016 — old 15%/no-FTS position is a common stale-source trap); equipment-royalty-in-definition-no-separate-rate; mli-ppt-applies-to-treaty-benefits; stale-source-hazard: several practitioner charts still list Indonesia as having no FTS provision (true only pre-2016).","pinpoint":"Article 12 (titled 'Royalties and Fees for Technical Services'), India–Indonesia DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Indonesia"}],"engine":"deterministic","llm_in_path":false}