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

Royalty: 10% of the gross amount — Article 12 (Royalties), India–Syria DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. This treaty has NO fees-for-technical-services article: FTS falls to business profits (PE required) or other income on the treaty's own terms — a structural feature, not an omission. The treaty contains no FTS/FIS article at all — the word 'technical' does not appear anywhere in the government-hosted text (verified by full-text search of the incometaxindia.gov.in version; article list runs Art 1–30 with Art 12 titled 'Royalties' only, and the signing Protocol adds nothing on services). Practitioner literature (Taxguru) confirms Syria is on the standard list of India DTAAs with no FTS clause (alongside Greece, Philippines, UAE-original, etc.). Consequence: technical/managerial service fees paid to a Syrian resident fall under Art 7 Business Profits (taxable in India only if a PE exists), Art 14 Independent Personal Services, or Art 22 Other Income — jurisprudence holds the domestic s.9(1)(vii)/s.115A FTS charge cannot be imported where the treaty deliberately omits FTS and the treaty is more beneficial. 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: NO_FTS_ARTICLE: service fees route through Art 7 (PE-dependent) / Art 14 / Art 22, not a withholding article — a rate engine must not emit an FTS rate for this corridor; EQUIPMENT_IN_ROYALTY_DEFINITION: ICS-equipment use is inside Art 12(3) at the same 10% — no separate equipment lane; HAS_LOB_ARTICLE: Article 27 Limitation of Benefits (uncommon for a 2008 India treaty of this type); SOURCE_RULE_EXTENSION: Art 12(5)(b) deems royalties to arise in the State of use when the standard payer rule fails — broader source rule than OECD model; GOVT_PAGE_METADATA_ERROR: the incometaxindia.gov.in page header lists 'Date of Signature 2009', but the notification text itself says signed 18 June 2008 — trust the treaty text, not the page metadata; SUPERSEDED_PRIOR_TREATY: the 1984 India–Syria agreement ceased to have effect when the 2008 agreement took effect.