What is the India–Taiwan (Chinese Taipei) treaty withholding rate on royalties and fees for technical services?

Royalty: 10% of the gross amount — Article 12, India–Taiwan (Chinese Taipei) DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — 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: Quasi-treaty: concluded between 'specified associations' (India-Taipei Association / Taipei Economic and Cultural Center), not sovereign states, and given effect under s.90A (not s.90) of the Income-tax Act — cite s.90A, not s.90, when claiming treaty benefit.; Treaty text uses 'territory' instead of 'Contracting State' throughout.; Single combined Art. 12 rate (10%) for royalties, equipment royalties, and FTS — no lane splits, unlike e.g. India-US.; Royalty definition includes equipment rental (ICS equipment) in treaty text, so equipment leasing takes the 10% treaty ceiling rather than falling to business profits..