[ compiled answer ]
law as at 14 Aug 2026 · settled
When does the 10% India–US royalty rate apply?
The compiled answer
Only in the equipment lane: Article 12(2)(b) taxes at 10% royalties for the use or right to use industrial, commercial or scientific equipment (Art 12(3)(b)) and fees for included services ancillary and subsidiary to the enjoyment of that equipment. Every other royalty and FIS case is 15% under Art 12(2)(a)(ii). Sources that state "India–US royalty/FTS = 10%" are generalising the equipment lane into an error.
compiled value: 10
Pinpoint
Article 12(2)(b) read with Article 12(3)(b), India–US DTAA (1990)
String-verified quote
“10 percent of the gross amount of the royalties or fees for included services”
source: rule:WHT.EQUIPMENT-RATE.INUS — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/india_us_equipment_royalty_10.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)