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

Royalty: 10% of the gross amount — Article 12 (Royalties), India–Namibia DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 14 (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-in-standalone-Article-14 (not Art 12) — non-standard numbering; Independent Personal Services is Art 15; equipment-use and computer-programme payments inside the Art 12(3) royalty definition at the same 10% rate (no separate equipment limb); flat 10% across dividends/interest/royalty/FTS; practitioner literature conflict: some sources wrongly list Namibia as a no-FTS treaty — primary text refutes this; no protocol, no MFN, never renegotiated since 1997.