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

Royalty: 10% of the gross amount — Article 12, India–New Zealand 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). 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-combined-with-royalty-in-single-article: Article 12 is titled 'Royalties and fees for technical services' and one 10% cap covers both; no-make-available: plain FTS definition, broader source-state taxing right than US/UK corridors; no-equipment-rate-split: equipment limb exists in the royalty definition but shares the general 10% rate; original-1986-rate-was-30-percent: sources quoting 30% are citing the pre-1999 text — as-amended rate today is 10%; no-MFN-clause: unlike Netherlands/France/Swiss corridors, the 10% needs no MFN or s.90(1) notification argument; domestic-rate-interaction: India's domestic s.115A rate on royalty/FTS is 20% (plus surcharge/cess) since FA 2023, so the treaty 10% is the operative planning rate (subject to TRC/Form 10F).