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

Royalty: 10% of the gross amount — Article 12 (Royalties), India–Botswana DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 13 (Technical Fees). 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 in a standalone Article 13 titled 'Technical Fees' — royalty/FTS split across Arts 12/13 rather than the usual combined Art 12; FTS definition is very broad: covers 'technical, managerial or consultancy' services payable 'to any person', with no make-available restriction and no construction/assembly or salaries exclusions; No protocol attached to the treaty at all — no MFN route to a lower rate; Domestic s.115A rate (20%+ since FY2023-24) exceeds the 10% treaty ceiling, so treaty relief is decisive for this corridor.