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

Royalty: 10% of the gross amount — Article 12 (Royalties), India–Tanzania 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 2011 treaty contains NO FTS/FIS article at all. Verified against the full CBDT-hosted text: the words 'technical', 'managerial' and 'fees for technical services' appear nowhere in the agreement; Article 12 covers royalties only and Article 13 is Capital Gains. The article sequence (1-32) has no FTS article and no Protocol. Consequence: technical/management service fees paid to a Tanzanian resident fall outside Art 12 and are taxable in India only as Business Profits (Art 7) if a PE exists — note the Art 5 service-PE clause (furnishing of services incl. consultancy through personnel for >183 days in any 12-month period) — or as Independent Personal Services (Art 14), else Other Income (Art 22). PwC's India WHT table concurs: Tanzania FTS = 'N/A' with footnote that in absence of a specific provision it is treated as business profits or IPS. Under Indian domestic law post-1.4.2023, absent treaty-PE taxability, s.115A 20% (+surcharge/cess) applies unless the no-FTS-article treaty position is taken. 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: one of the minority of Indian treaties with no FTS/FIS article — technical service fees route through Art 7/Art 14/Art 22, a materially taxpayer-favourable position vs the 20% domestic s.115A rate.; SERVICE_PE: Art 5 contains a service-PE clause (services incl. consultancy >183 days in any 12-month period) — the backstop that catches service fees the missing FTS article lets through.; EQUIPMENT_ROYALTY_IN_DEFINITION: equipment-use payments are inside the Art 12(3) royalty definition at the same 10% — no separate equipment lane (contrast India–US 12(2)(b)).; UNUSUAL_SOURCE_RULE: Art 12(5)(b) adds a place-of-use deeming rule — royalties not otherwise arising in a State are deemed to arise where the right/property is used.; LOB_ARTICLE: Art 28 (Limitation of Benefits) present in the treaty text.; SUPERSEDED_PREDECESSOR: sources citing 20% royalty rates reflect the defunct 1979 treaty — a common stale-data trap for this corridor..