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

Royalty: 10% of the gross amount — Article 12 (titled 'Royalties' but covering both royalties and fees for technical services), India–Kuwait DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12 — FTS is folded into the Royalties article (defined at Art 12(3)(b), rate at Art 12(2)); there is no standalone FTS 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-royalty-article: no standalone FTS article — FTS is defined and rate-capped within Article 12 'Royalties'; no-make-available: plain broad FTS definition, no technology-transfer restriction; no-separate-equipment-rate: equipment royalties sit in the general 10% royalty definition; single-flat-rate-treaty: 10% across dividends/interest/royalties/FTS.