{"query":"What is the India–Uganda treaty withholding rate on royalties and fees for techn","matches":[{"id":"auto_wht_uganda","question":"What is the India–Uganda treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 10% of the gross amount — Article 12 (combined 'Royalties and Fees for Technical Services'), India–Uganda 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). 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 share a single Article 12 with one undifferentiated 10% rate — no equipment/copyright rate splits of the kind seen in the India–US treaty.; FTS definition lacks make-available — materially broader source taxation than US/UK-style treaties; do not import make-available reasoning into this corridor.; Equipment leasing is a royalty under Art 12(3)(a) at 10%, not business profits.; FTS carve-out references Articles 14 AND 15 (independent and dependent personal services).; No protocol, no MFN clause, no MLI overlay — the 2004 text is the complete in-force instrument.; Treaty 10% ≈ domestic s.115A 10% base rate: treaty election is often about avoiding surcharge/cess and securing PE-based thresholds, not a rate cut..","pinpoint":"Article 12 (combined 'Royalties and Fees for Technical Services'), India–Uganda DTAA","confidence":"verified","as_at":"14 Aug 2026","match_score":2,"treaty":"India–Uganda"}],"engine":"deterministic","llm_in_path":false}