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

Royalty: 10% of the gross amount — Article 12 (Royalties and Fees for Technical Services), India–China DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12 (combined with 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 Services' with one 10% rate for both; equipment-royalty limb present in Art 12(3) definition but no separate rate; FTS definition carve-out for Art 5(2)(k) service-PE activities and Art 15 employment income; no MFN clause in this corridor; treaty substantively renegotiated by 2018 BEPS protocol but WHT articles left untouched.