{"query":"What is the India–Poland treaty withholding rate on royalties and fees for techn","matches":[{"id":"auto_wht_poland","question":"What is the India–Poland treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 15% of the gross amount — Article 13 (Royalties and Fees for Technical Services), India–Poland DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 15%. FTS: 15% — Article 13 (combined with 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: Royalties and FTS sit in ARTICLE 13, not Article 12 — models trained on the OECD pattern routinely miscite the article number for this treaty.; FTS definition excludes payments 'mentioned in Articles 15 and 16' (IPS and Dependent Personal Services here), i.e. the whole personal-services numbering is shifted vs the model convention.; No make-available condition and no MFN route to import one — the 15% gross FTS taxation is broad.; Equipment royalties are inside the general royalty definition at the same 15% — no reduced equipment lane (contrast India–US 10% equipment lane).; Legacy pre-2014 texts citing 22.5% still circulate; the in-force rate since 1 April 2015 (India) is 15%.; CBDT page metadata is internally inconsistent ('Date of Signature 1990' vs signature 21 June 1989, EIF 26/10/1989) — trust the notification recitals, not the header fields..","pinpoint":"Article 13 (Royalties and Fees for Technical Services), India–Poland DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Poland"}],"engine":"deterministic","llm_in_path":false}