{"url":"https://lrlabs.ai/t/auto_wht_austria","engine":"deterministic","llm_in_path":false,"id":"auto_wht_austria","question":"What is the India–Austria 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–Austria 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 (equipment limb taxed at the same 10%); no MFN clause in protocol; employee-payment exclusion written into the FTS definition; 1999 treaty replaced the old 1963 India-Austria agreement.","pinpoint":"Article 12 (combined \"Royalties and Fees for Technical Services\"), India–Austria DTAA","confidence":"verified","as_at":"14 Aug 2026","treaty":"India–Austria"}