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

Royalty: 10% of the gross amount — Article 12 (combined Royalties and Fees for Technical Services article), India–Slovenia DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12. 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 royalty+FTS article at one flat 10% rate — no equipment lane, no rate splits of any kind; FTS includes 'managerial' services and lacks make-available: one of the broader FTS definitions in India's network; do not analogize from US/UK-style FIS; No MFN clause in this treaty despite Slovenia being the third-state benchmark in the Nestle SA MFN litigation — a common confusion worth an explicit engine rule; Protocol point 4 permits India to tax a PE of a Slovenian company at up to 15 percentage points above the domestic-company rate (branch-rate differential cap); MLI PPT applies to this treaty — treaty benefit (10% rate) can be denied for principal-purpose arrangements; FTS carve-out references Arts 14 and 15 (independent/dependent personal services) only — no exclusion for teaching or construction-linked services beyond that.