Tax alert: Guarantee fees taxable but not as ‘interest’ has been saved
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Tax alert: Guarantee fees taxable but not as ‘interest’
7 August 2024
The Delhi High Court, based on the facts of the case, has held that guarantee fees received by the taxpayer from Indian subsidiaries in lieu of guarantee provided to overseas financial institutions who extended credit facilities to Indian subsidiaries, would accrue or arise in India but would not qualify as ‘interest’ under Article 12 of the India-UK tax treaty.
