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

Royalty: 20% of the gross amount — Article 13, India–Italy DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 20%. FTS: 20% — Article 13 (combined 'Royalties and Fees for Technical Services' article). 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-combined-royalty-FTS-article (single Article 13 covers both); rate-at-20-treaty-cap-equals-domestic-base-rate — treaty confers little/no rate benefit versus s.115A/ITA-2025 20% (benefit limited to avoiding surcharge/cess); wide FTS definition with no make-available and no MFN escape — one of India's least favourable FTS corridors; equipment royalties included in royalty definition at the same 20% (no reduced equipment limb); tax-sparing clause in Art 24(4)(b) referencing repealed 1961-Act incentives (aging-treaty indicator; treaty not renegotiated since 1993).