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

Royalty: 10% of the gross amount — Article 12, India–Serbia DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 13 (standalone FTS article, separate from Art 12 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 lives in a STANDALONE Article 13, not inside Article 12 — a rate engine keyed to 'Article 12 = royalty+FTS' will miss this treaty's FTS article entirely.; Article numbering shifted vs OECD model: Royalties 12, FTS 13, Capital Gains 14, Independent Personal Services 15 — cross-references (e.g. FTS carve-out to 'articles 15 and 16', PE/effective-connection fallback to 'article 7 or article 15') use the shifted numbers.; Equipment-use payments are royalties under Art 12(3) at the same 10% — no separate equipment lane, unlike India–US 12(2)(b).; Broad FTS with NO make-available filter — managerial/technical/consultancy services taxable at source at 10% regardless of technology transfer.; Treaty concluded with the defunct 'Serbia and Montenegro' state union; applies to Serbia (and separately Montenegro) by succession — name-matching on 'Serbia' alone can miss the notified text.; Since Finance Act 2023, India's domestic s.115A rate on royalty/FTS is 20% (plus surcharge/cess), so the treaty 10% is now materially beneficial — TRC and Form 10F needed to claim it; MLI PPT applies to the claim..