What is the India–Finland 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–Finland 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 Article 12, one 10% rate); treaty-renegotiated-2010 — replaced the 1983 treaty; stale practitioner literature still cites old Art 13(4)(c) make-available language, a trap for compiled rules; make-available-absent despite Finland appearing on common 'make available treaty' lists (those lists reference the terminated 1983 treaty); MFN-clause-in-protocol (prospective-only, OECD-member trigger, express notification requirement) currently dormant for royalty/FTS; equipment-royalty limb included in royalty definition but no separate rate; MLI-modified (synthesised text; PPT) — no rate impact.