What is the India–Norway 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–Norway DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12 (same article as 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-inside-royalty-article: royalties and FTS share a single combined Article 12 with one 10% rate; no make-available restriction — broad managerial/technical/consultancy FTS definition (broader source taxation than US/UK corridors); equipment royalties included in the royalty definition but carry the same 10% rate (no separate equipment limb rate); no MFN clause in this corridor; 2011 treaty replaced the 1986 treaty — pre-2012 secondary sources citing tiered/higher rates are stale.