{"query":"What is the India–Lithuania treaty withholding rate on royalties and fees for te","matches":[{"id":"auto_wht_lithuania","question":"What is the India–Lithuania treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 10% of the gross amount — Article 12, India–Lithuania 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 'Royalties and Fees for Technical Services' 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-combined-with-royalty-in-single-article-12; flat-10-percent-no-rate-splits (equipment royalties same 10%); no-make-available-restriction (broad managerial/technical/consultancy FTS definition); no-MFN-clause-in-protocol; third-state-treaty-in-Nestle-MFN-litigation (its 5% dividend rate was the rate claimed under NL/CH/FR MFN clauses after Lithuania's 2018 OECD accession); MLI-covered (PPT applies to treaty benefit claims).","pinpoint":"Article 12, India–Lithuania DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Lithuania"}],"engine":"deterministic","llm_in_path":false}