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

Royalty: 10% of the gross amount — Article 12, India–Brazil DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12-A. 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: treaty-renegotiated-recently: amending Protocol effective in India only from 1 Apr 2026 — engines must version-switch rates at that date; historic FTS-inside-royalty-definition: pre-amendment, technical services/assistance were deemed royalties via 1988 Protocol Item 3 (15% rate); standalone Art 12-A exists only from the 2026 effective dates; trademark-royalty rate split: 15% trademarks vs 10% all other royalties (formerly 25%/15% — a rates-above-20 case historically); staggered effective dates: Brazil WHT from 1 Jan 2026, India from 1 Apr 2026; Art 12-A(3) extended to technical-assistance payments by Protocol point 6; no make-available restriction in FTS article and no MFN clause in the corridor.