What is the India–Kazakhstan 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' article), India–Kazakhstan 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 combined article as royalties; FTS defined at Art 12(3)(b)). 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: combined-royalty-and-FTS-article (single Art 12 with one 10% rate for both limbs); royalty-definition-expressly-includes-software; no-separate-equipment-rate (equipment limb inside royalty definition at same 10%); MFN-clause-deleted-by-2017-protocol (databases showing the 1996 MFN clause are stale); pre-deletion MFN clause was any-third-State, not OECD-restricted (historical-period claims only); FTS carve-out for Art 14/15 services.