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

Royalty: 10% of the gross amount — Article 12, India–Estonia 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 Art 12 'Royalties and Fees for Technical Services'); equipment-use in royalty definition but no separate rate limb; MLI-covered agreement (PPT applies to treaty benefits); quasi-MFN in Protocol Ad Art 5 limited to insurance-PE deeming, not rates.