{"query":"What is the India–Montenegro treaty withholding rate on royalties and fees for t","matches":[{"id":"auto_wht_montenegro","question":"What is the India–Montenegro treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 10% of the gross amount — Article 12, India–Montenegro DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 13. 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: succession-treaty: concluded with the State Union of Serbia and Montenegro (2006) and continues for Montenegro by succession — most databases list it under Serbia; the same text governs both corridors; atypical-numbering: Royalties = Art 12, FTS = separate Art 13, Capital Gains = Art 14 (many India treaties put royalty+FTS together in one article); equipment-use inside royalty definition (industrial/commercial/scientific equipment) with no separate rate; plain FTS definition — no make-available restriction, no MFN route to one; no MFN clause in protocol.","pinpoint":"Article 12, India–Montenegro DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Montenegro"}],"engine":"deterministic","llm_in_path":false}