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

Royalty: 10% of the gross amount — Article 12, India–Cyprus 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 royalties and FTS article). 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 for royalties and FTS); no-make-available (plain FTS definition — broader Indian taxing right than US/UK corridors); treaty-renegotiated-recently (2016 full replacement of the 1994 treaty, effective 1 Apr 2017); former-s94A-notified-jurisdiction (2013–2016, rescinded retrospectively — legacy 30% WHT cases may appear in older material); equipment-royalty-in-definition-same-rate (no separate equipment limb rate); MLI-PPT-applies (treaty benefit conditional on principal-purpose test from 1 Apr 2021).