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

Royalty: 10% of the gross amount — Article 12, India–Iran DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 13. 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: standalone-FTS-article-13 (FTS is its own Article 13 rather than combined into Art 12, shifting subsequent article numbering by one); equipment-royalty-inside-royalty-definition-same-rate; no-make-available-restriction; recent-treaty (signed 2018, effective in India only from FY 2021-22 — pre-2018 there was no comprehensive India–Iran DTAA, only a limited air-transport agreement); no-MFN-clause.