What is the India–Morocco 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'), India–Morocco DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12. 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-single-article (Art 12 covers both under one 10% cap); equipment-royalty limb present in royalty definition at same 10% (Art 12(3)(b)); no-make-available restriction on FTS; Art 14 opens with an express carve-out cross-reference to Art 12 FTS; treaty rate (10%) is below India's domestic s.115A rate (20% plus surcharge/cess post-FA 2023), so treaty relief is material.