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

This treaty sets NO ceiling on the source-state rate — Article 13 (Article XIII), India–Egypt DTAA, allocates taxing rights without capping them. There is therefore no treaty rate to claim: Indian domestic law governs in full at 20% on gross plus surcharge and cess (s.207(2), Income-tax Act 2025 — 20.8%/21.84% effective). Any figure quoted as the 'India–Egypt treaty rate' is the DOMESTIC charge mislabelled. Equipment-use royalties sit inside the royalty definition and take the same None%. This treaty has NO fees-for-technical-services article: FTS falls to business profits (PE required) or other income on the treaty's own terms — a structural feature, not an omission. The 1969 treaty has NO FTS/FIS article and technical-service fees are not folded into the Art 13 royalty definition either. Consequence: FTS falls to Article 23 (Income not expressly mentioned), which expressly preserves each state's domestic law ('The laws in force in either of the Contracting States will continue to govern assessment and taxation of income... except where express provision to the contrary is made'). Note this Art 23 is the OPPOSITE of a residence-only Other Income article — it gives no treaty shelter, unlike the India–UAE no-FTS position where taxpayers argue business-profits/other-income relief. So Indian-source FTS paid to Egyptian residents is taxed at the domestic s.115A rate of 20% plus surcharge/cess (effective up to ~21.84%), or as business profits if a PE exists. make_available is 'absent' only in the trivial sense that no FTS article exists; there is no make-available relief of any kind. Confirmed against full government-hosted treaty text plus Taxguru chart ('No separate provision' for FTS; footnote: Articles 11, 12 and 13 provide no WHT rates, tax withheld per Income-tax Act 1961) and Orbitax summary (treaty does not deal with technical/management service 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: no-FTS-article; royalty-no-treaty-rate-cap: Art 13 grants exclusive source-state taxation with no ceiling — domestic law (s.115A 20% + surcharge/cess) applies; a compiled engine must NOT emit a '10%/15% treaty rate' for this corridor; equipment-limb-inside-general-royalty-definition-no-separate-rate; other-income-article-preserves-domestic-law (Art 23 is not a residence-only clause — no treaty shelter for uncovered income, unlike India–UAE); pre-OECD-1969-vintage-treaty: dividends/interest (Arts 11-12) also uncapped; source uses Roman numerals (Article XIII) in original; effective-rate-exceeds-20-with-surcharge-cess (~21.84% for foreign companies).