What is the India–US treaty withholding rate on royalties and fees for included services?

15% of the gross amount — Article 12(2)(a)(ii), India–US DTAA. The five-year 20%/15% tier in Art 12(2)(a)(i) expired in the 1990s, so 15% is the general rate for Art 12(3)(a) royalties and fees for included services. The widely-repeated "10%" is WRONG for the general case: 10% applies only under Art 12(2)(b) to equipment royalties (Art 12(3)(b)) and FIS ancillary and subsidiary to the enjoyment of that equipment. The treaty rate is on gross with no surcharge or cess, against a domestic 20% + surcharge + cess (s.207(2), Income-tax Act 2025) — so treaty entitlement (TRC + Form 10F under s.159(8)) decides almost every US remittance.