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

Royalty: 10% of the gross amount — Article 12, India–Kenya DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 13 — Fees for Management, Professional and Technical Services. 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-is-fmpts: Article 13 covers management, professional AND consultancy fees, wider than India's usual FTS scope; equipment-royalty-inside-royalty-definition at same 10% rate (no separate limb); no-make-available anywhere (text or protocol); no-protocol / no-MFN corridor; treaty-renegotiated-recently: 2016 treaty replaced 1985 treaty effective 2018; domestic-rate-interaction: India's domestic s.115A rate on royalty/FTS is 20% (+surcharge/cess) since FA 2023, so the 10% treaty rate is the operative cap (TRC + Form 10F needed).