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

Royalty: 10% of the gross amount — Article 12 (titled "Royalties and Fees for Technical Services"), India–Mexico 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 — FTS defined in 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: fts-inside-royalty-article: single combined Article 12 covers both royalties and FTS at one 10% rate; protocol-expands-royalty-definition: satellite/cable transmission rights and contingent alienation proceeds (notwithstanding Art 13 capital gains) treated as royalties; equipment-royalty-same-rate: equipment limb present in Art 12(3)(a) but no separate rate; no-make-available-and-no-mfn-route: broad FTS definition with no treaty or protocol path to a make-available restriction.