What is the India–Armenia 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–Armenia 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 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, one 10% rate for both); no-separate-equipment-royalty-rate (ICS equipment limb inside royalty definition at same 10%); no-make-available-restriction (broad FTS definition); detailed Limitation of Benefits article (Article 29) with 50% ownership/base-erosion tests and main-purpose rule — unusual for a 2003 Indian treaty; non-standard article numbering at the tail: LOB Art 29, diplomatic Art 30 (entry into force follows); 2018 amending notification modernised EOI/collection-assistance articles only.