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

Royalty: 30% of the gross amount — Article 12 (combined "Royalties and Fees for Technical Services"), India–Slovak Republic DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 30%. FTS: 30% — 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: Single combined Article 12 covers BOTH royalties and FTS at one undifferentiated 30% gross rate — one of the highest FTS/royalty caps in India's treaty network (1986 vintage).; Treaty rate (30%) exceeds India's domestic s.115A royalty/FTS rate (20% + surcharge/cess since Finance Act 2023), so s.90(2) makes domestic law the operative regime; the treaty matters mainly for definitional/PE/other-article purposes, not the rate.; Equipment royalties are inside the Art 12(3) royalty definition with no reduced equipment lane.; FTS definition has no make-available limitation and no exclusions carve-out paragraph (unlike India-US/UK Art 12) — very broad scope.; The treaty text is a succession instrument: India hosts the SAME 1986 Czechoslovakia text under both its Czech Republic and Slovak Republic entries is not the case — Czech Republic has its own 1998 treaty (10% royalty/FTS), while Slovakia remains on the 1986 Czechoslovakia text; do not conflate the two corridors.; Applicability to Slovakia rests on state-succession plus a s.119 CBDT clarification (SO 813(E), 2015) rather than a standalone s.90(1) notification naming Slovakia.; UNUSUAL RATE: 30% — confirmed against primary text by adversarial verification; well outside the usual 10-15% band, so expect published charts to disagree.