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

Royalty: 15% of the gross amount — Article 12 (combined 'Royalties and fees for technical services'), India–Belarus DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 15%. FTS: 15% — 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: rate-above-10-standard: 15% is higher than the 10% India now agrees with most partners; FTS-and-royalty-in-single-article: one combined Article 12 with a single 15% cap; equipment-royalty-limb-present-but-no-rate-split; no-make-available-restriction: plain FTS definition, broader source taxation than US/UK-style treaties; no-MFN-clause-in-protocol; domestic-rate-flip-2023: post-Finance Act 2023 the treaty 15% undercuts the 20%+ s.115A domestic rate, making treaty access outcome-determinative.