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

This treaty sets NO ceiling on the source-state rate — Article VII, India–Greece 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–Greece treaty rate' is the DOMESTIC charge mislabelled. The equipment limb is NOT in this treaty's royalty definition, so payments for the use of equipment fall outside the royalty article altogether — they are business profits (PE required) or other income on the treaty's own terms, NOT taxable at the royalty rate. 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 1965 treaty has NO FTS/FIS article — the term does not appear anywhere in the text (verified against the full agreement). Consequence: FTS cannot default cleanly to business profits either, because Art III(3) expressly EXCLUDES 'management charges' and 'remuneration for labour or personal services' from 'industrial or commercial profits'. Per Art XVII(1) ('the laws in force in either of the territories will continue to govern... except where express provision to the contrary is made'), FTS paid by an Indian payer to a Greek resident is taxed per Indian domestic law: s.9 deeming + s.115A at 20% base (~20.8–21.84% effective). PwC footnote for treaties without an FTS provision: 'In absence of specific provision, it may be treated as business profits or independent personal services under respective tax treaties, whichever is applicable' — but for Greece specifically PwC marks all three income rows N/A with 'Taxable in the country of source as per domestic tax rates.' For individual/professional services, Art XIV (personal services, 183-day rule) may instead apply. No make-available concept exists anywhere in this corridor. 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; no-royalty-rate-cap-in-treaty (domestic-law rate governs: 20% base s.115A, effective >20 with surcharge/cess); pre-OECD-model-1965-treaty: exclusive source taxation ('may be taxed only in that other territory') for royalties, interest, dividends — not the shared-taxation-with-cap model; management-charges-and-personal-services-remuneration expressly excluded from business-profits article (Art III(3)) — FTS cannot shelter under Art III; mining/quarry/natural-resource royalties carved out of Art VII into Art X (immovable property); no-protocol-no-MFN; practitioner-chart-trap: multiple secondary sources publish '10%' for Greece royalties — that is the obsolete pre-2023 domestic rate, not a treaty rate; a compiled engine copying it would be wrong by 10+ points.