What is the India–Albania treaty withholding rate on royalties and fees for technical services?

Royalty: 10% of the gross amount — Article 12 (combined 'Royalties and Fees for Technical Services'), India–Albania DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12 (same combined article as 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: FTS-inside-royalty-article (single combined Article 12 covers both royalties and FTS); no-make-available-restriction (plain managerial/technical/consultancy definition); no-protocol-no-MFN; no-equipment-rate-split (equipment limb in royalty definition but same 10% rate); source-rule tail in Art 12(5)(b): royalties/FTS deemed to arise where property is used or services performed when 5(a) does not allocate them; note: domestic s.115A rate is 20% (plus surcharge/cess) since FA 2023, so the treaty 10% is the operative cap for non-residents with valid TRC.