{"query":"What is the India–Sri Lanka treaty withholding rate on royalties and fees for te","matches":[{"id":"auto_wht_sri_lanka","question":"What is the India–Sri Lanka treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 10% of the gross amount — Article 12 (Royalties and Fees for Technical Services), Art 12(2), India–Sri Lanka 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), definition at Art 12(3)(b), rate at Art 12(2). 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: OLD-TREATY CONTAMINATION RISK: widely circulated PDFs (including Taxsutra's hosted 'SRI LANKA DTAA.pdf') and much commentary reproduce the 1982 Convention, which had NO FTS article — any source saying 'India–Sri Lanka has no FTS clause' is describing the superseded treaty; Protocol clause (ii) 'more beneficial domestic law prevails' is a rare treaty-wide domestic-law override — relevant since India's domestic royalty/FTS rate rose to 20% (plus surcharge/cess) from FY 2023-24, making the treaty 10% the operative rate, but the clause could matter for other income streams; FTS definition is broad (managerial/technical/consultancy) with no make-available filter and sits in a combined Art 12 with royalties at an identical 10% — classification disputes between royalty/FTS/business profits are low-stakes on rate; PPT applies from 1 April 2027 (Indian fiscal years) — beneficial-owner plus PPT gating of the 10% rates from that date; Treaty retains Article 14 (Independent Personal Services); FTS definition carves out Arts 14 and 15 payments.","pinpoint":"Article 12 (Royalties and Fees for Technical Services), Art 12(2), India–Sri Lanka DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Sri Lanka"}],"engine":"deterministic","llm_in_path":false}