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

Royalty: 10% of the gross amount — Article 12 — Royalties and Fees for Technical Services (combined article), India–Sudan 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: Combined article: royalties and FTS share one Article 12 with a single undifferentiated 10% cap — no equipment lane, no rate splits of any kind.; Broad Indian-model FTS with no make-available filter — managerial, technical or consultancy services are all caught at source; do not import make-available reasoning from the US/UK treaties into this corridor.; FTS definition carves out Articles 14 and 15 (independent and dependent personal services) rather than the more common Art 15-only carve-out.; No protocol, no MFN clause, no MLI modification — the in-force text is the 2003 signature text unchanged; any claimed rate other than 10% for royalty/FTS in this corridor is a hallucination signal.; Since Finance Act 2023 raised the s.115A domestic rate on royalty/FTS to 20% (plus surcharge/cess), the treaty 10% is the operative beneficial rate — TRC and Form 10F required to access it.; Under Art 29, India-side effectivity began with fiscal years from 1 April following entry into force (EIF 15 April 2004 → effective India-side from 1 April 2005; Sudan-side from 1 January 2005)..