{"url":"https://lrlabs.ai/t/auto_wht_denmark","engine":"deterministic","llm_in_path":false,"id":"auto_wht_denmark","question":"What is the India–Denmark treaty withholding rate on royalties and fees for technical services?","answer":"Royalty: 20% of the gross amount — Article 13 (combined 'Royalties and fees for technical services'), India–Denmark DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 20%. FTS: 20% — Article 13. 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-combined-royalty-fts-article (single Art 13 covers both); rate-at-20 — highest tier among Indian treaties; treaty now offers no rate benefit over domestic s.115A 20% (post-Finance Act 2023) except surcharge/cess relief; nonstandard-article-numbering (dividends 11, interest 12, royalties/FTS 13); no-make-available and no-MFN — plain-vanilla wide FTS definition; first-five-years rate tiers exist in the treaty but only in Art 9 (shipping), not royalty/FTS; trilingual treaty (Danish/Hindi/English) with English text operative on divergence.","pinpoint":"Article 13 (combined 'Royalties and fees for technical services'), India–Denmark DTAA","confidence":"verified","as_at":"14 Aug 2026","treaty":"India–Denmark"}