What is the India–Fiji 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–Fiji 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: no standalone FTS article — royalties and FTS share Article 12 with one combined 10% cap; no-make-available: plain Indian-model FTS definition, no knowledge-transfer test in text or protocol; no-separate-equipment-rate: equipment limb sits in the royalty definition at the same 10%; no-MFN-clause in the Protocol; capital gains is Article 13 (not royalties) — engines that assume Art 13 = FTS for Indian treaties will mis-map this corridor; Protocol clause 2 expressly preserves residence-state taxation wherever 'may be taxed in the other State' appears.