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

Royalty: 10% of the gross amount — Article 12 (combined 'Royalties and Fees for Technical Services'), India–Georgia DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12 (same article as 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 covers both royalties and FTS at one 10% cap; no-equipment-rate-split: equipment-use payments are royalties under Art 12(3)(a) but take the same 10% general rate; plain-FTS-definition-no-make-available: treaty FTS is broader than make-available treaties (US/UK style), so pure managerial/consultancy fees are caught — but capped at 10%, below India's domestic s.115A 20%+ rate, making the treaty rate the operative one subject to TRC/PPT; MLI-PPT-applies: benefit of the 10% cap can be denied under the MLI principal purpose test.