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

Royalty: 10% of the gross amount — Article 12 (Royalties and Fees for Technical Services — combined article; same article number and 10% rate in both the 1999 treaty and the revised 2025 treaty), India–Qatar 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: combined-royalty-and-FTS-article (single Art 12 covers both, one 10% rate); treaty-renegotiated-recently (2025 replacement treaty effective 1 Apr 2026 — the treaty in force TODAY is the new one; BEPS-aligned PPT, expanded PE, fiscally transparent entities); equipment-royalty-limb-inside-royalty-definition at same 10% rate (no split); no-make-available-condition despite low 10% rate.