What is the India–Russia 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–Russia 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+FTS article (Art 12) with a single 10% rate — no equipment/general split, unlike India-US Art 12.; Royalty definition expressly includes 'computer software programme' — broader than OECD Model; software payments are explicitly royalties in this treaty.; FTS has no make-available condition — broad taxing right; do not import one via MFN (none exists in this corridor).; Protocol para 3's 'most favoured' language applies ONLY to PE taxation, a common source of false-positive MFN claims for this treaty.; Protocol para 2 creates an unusual 10% cap on supervisory-activity fees for qualifying turnkey projects (routed through the Art 12 rate).; MLI-synthesised text in force (PPT applies); treaty remains operative despite geopolitical developments — no suspension by India as of Aug 2026 (unlike Russia's suspension of certain treaties with 'unfriendly' western states, which does not include India)..