Taxation rate for royalties: lower treaty rate applied to cross-border payments to Canada after a subsequent OECD convention change. Direction establishing a reduced withholding rate on royalties and fees for technical services paid by a resident of India to a resident of Canada where payment relates to rights first granted, or contracts signed, after the entry into force of a later OECD-member convention under which India accepted a lower rate; the directive is issued under section 90 of the Income-tax Act and the relevant surtax provision to apply that lower rate automatically.