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

Royalty: 10% of the gross amount — Article 12 (combined: Royalties and Fees for Technical or Professional Services), India–Bhutan 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 'Royalties and Fees for Technical or Professional Services'; FTS-definition-wider-than-usual: expressly covers professional services (physicians, lawyers, engineers, accountants, etc.), not just managerial/technical/consultancy; no-separate-equipment-royalty-rate: equipment limb sits inside the royalty definition at the same 10%; protocol-domestic-law-more-beneficial-clause: source-State domestic law applies if more beneficial than the treaty (relevant post-Finance Act 2023 when domestic royalty/FTS rate rose to 20% — treaty 10% remains the cap); no-make-available-restriction.