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

Royalty: 10% of the gross amount — Article 12, India–Latvia 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 'Royalties and Fees for 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-inside-combined-royalty-FTS-article (single Art 12 covers both); no-make-available (plain managerial/technical/consultancy FTS definition); no-separate-equipment-rate (equipment use taxed as royalty at the uniform 10%); recent-vintage treaty (2013) already at the 10% flat structure — no first-five-years tiers or government-payer splits.