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

Royalty: 10% of the gross amount — Article 13, India–Bangladesh DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. This treaty has NO fees-for-technical-services article: FTS falls to business profits (PE required) or other income on the treaty's own terms — a structural feature, not an omission. The treaty contains NO FTS/FIS article — verified against the full notified text (32 articles; Art 13 Royalties is the only royalty/technical-payments provision, and 'fees for technical services' appears nowhere in the treaty or the 2013 Protocol). Consequence: technical-service fees paid to a Bangladesh resident fall under Art 7 Business Profits (taxable in India only if a PE exists) or Art 15 Independent Personal Services — PwC's India WHT matrix confirms this ('N/A — in absence of specific provision, it may be treated as business profits or independent personal services'). Practitioners therefore often obtain NIL Indian WHT on pure services absent a PE, subject to s.90(4) TRC/Form 10F compliance; India's 20% domestic s.115A rate applies only if treaty relief is not claimed. make_available is set to 'absent' only as a schema placeholder — there is no FTS clause at all (structural flag no-FTS-article governs). 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: no-FTS-article; equipment-royalty-inside-royalty-definition-same-rate; royalty-definition-excludes-mineral-deposit-and-natural-resource-payments; royalties-at-Article-13-not-12 (treaty numbering offset: Interest=12, Royalties=13, Capital gains=14); services-default-to-Art-7/Art-15-PE-test-absent-FTS-article.