Taxability of Guarantee fee paid

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What is taxability of Guarantee fee paid by Indian Company to its Non- resident Associated Company for providing Guarantee to bank for providing Loan to Indian Company ?

Please, provide relavant section under Income tax.
Replies (3)
It is taxable in indian since Guarantee commission is earned in India by non-resident company.

company paying commission will be required to deduct TDS under section 195.
But, Guarantee fee can be also treated as Interest or incidental charges ?

Guarantee commission is treated as Interest or incidental charges for Indian Company. 


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