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

Royalty: 10% of the gross amount — Article 12 — Royalties and Fees for Technical Services, India–Trinidad and Tobago DTAA (as amended through 20 Aug 2026). Equipment-use royalties sit inside the royalty definition and take the same 10%. FTS: 10% — Article 12 — Royalties and Fees for Technical Services (combined article). 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 royalty + FTS in a single Article 12 at a uniform flat 10% — no equipment or copyright sub-lanes.; Royalty definition explicitly names 'computer software programme' — unusual and pro-Revenue on software payment characterisation disputes.; Royalty definition includes industrial/commercial/scientific equipment, so equipment leasing is treaty-royalty at 10% (no separate lane).; FTS has NO make-available condition — broad managerial/technical/consultancy formulation; taxpayers cannot borrow a make-available filter, and there is no protocol to import one.; FTS definition excludes only Art 14/15 personal-services payments (no exclusion for construction/assembly PE-type activities).; T&T-side instrument is an Order under s.93(1) of the T&T Income Tax Act Chap. 75:01; English text prevails over Hindi on divergence..