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

Royalty: 10% of the gross amount — Article 12, India–Japan 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; definition in Art 12(4)). 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 Art 12 for royalties and FTS); no-make-available-restriction (plain managerial/technical/consultancy FTS definition — broader source taxation than US/UK corridors); no-separate-equipment-rate (equipment-use payments sit inside the royalty definition at the same 10%); no-MFN-clause; MLI-modified treaty (PPT applies as a treaty-benefit gate on the 10% rate).