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

Royalty: 10% of the gross amount — Article 12 (Royalties and Fees for Technical Services), India–Romania 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 — there is no separate FTS 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 is combined into Article 12 with royalties — a query expecting a separate FTS article (or Art 13 = FTS) will misfire; Art 13 here is Capital Gains.; Stale-text hazard: the superseded 1987 treaty (22.5% royalty/FTS) is still widely mirrored online (taxsutra PDF, aseanbriefing, old law.incometaxindia pages) — any 22.5% figure is the dead treaty.; No make-available filter and a broad FTS definition including 'services of technical or other personnel' — managerial fees are squarely covered.; Equipment leasing is taxed as royalty at the same 10% (in-definition), not a separate lane and not excluded.; Article 27 Limitation of Benefits exists in the treaty itself, on top of the MLI PPT.; Art 13(4): gains from alienation of shares of a company resident in a State may be taxed in that State — source-state share-gain taxation with no participation threshold.; Deemed-source rule Art 12(5)(b): FTS deemed to arise where services are PERFORMED when the normal payer-residence rule fails — unusual tiebreak worth encoding..