What is the India–North Macedonia 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–North Macedonia 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 in a single article). 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 for royalties and FTS); no-equipment-rate-split (flat 10% across all royalty categories); corridor-name-drift (treaty concluded with 'Republic of Macedonia'; state renamed North Macedonia in 2019 — lookups under either name must resolve to the same 2013 treaty).