The Resource Case note : lender's fees not linked to loan are not interest income
Case note : lender's fees not linked to loan are not interest income
Resource Information
The item Case note : lender's fees not linked to loan are not interest income represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Case note : lender's fees not linked to loan are not interest income represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- This case note sets out the ruling by the Authority for Advance Rulings in Societe de Promotion et de participation pour la cooperation economique that an appraisal front-end fee charged by the taxpayer to its client borrowers was not taxable in India as interest because it was not linked to the loan and not payable if the loan was not approved. However, all other fees (i.e. non-appraisal front-end fees, commitment fees, cancellation fees, monitoring fees and amendment fees) were taxable in India as interest income in terms of article 12(4) of the France-India Income and Capital Tax Treaty (1992) because they were payable only after the debt claim came into existence
- Language
- eng
- Label
- Case note : lender's fees not linked to loan are not interest income
- Title
- Case note : lender's fees not linked to loan are not interest income
- Language
- eng
- Summary
- This case note sets out the ruling by the Authority for Advance Rulings in Societe de Promotion et de participation pour la cooperation economique that an appraisal front-end fee charged by the taxpayer to its client borrowers was not taxable in India as interest because it was not linked to the loan and not payable if the loan was not approved. However, all other fees (i.e. non-appraisal front-end fees, commitment fees, cancellation fees, monitoring fees and amendment fees) were taxable in India as interest income in terms of article 12(4) of the France-India Income and Capital Tax Treaty (1992) because they were payable only after the debt claim came into existence
- Citation source
- In: Asia-Pacific tax bulletin. - Amsterdam. - Vol. 24 (2018), no. 5 ; 3 p
- http://library.link/vocab/creatorName
-
- Dugar, A
- Bhandari, L
- Geographic coverage
- Asia
- Language note
- English
- http://library.link/vocab/subjectName
-
- case law
- advance ruling
- loan
- interest
- fee
- income classification
- tax treaty
- Label
- Case note : lender's fees not linked to loan are not interest income
- Label
- Case note : lender's fees not linked to loan are not interest income
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Case-note--lenders-fees-not-linked-to-loan-are/EsZIrQ1Dc5A/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Case-note--lenders-fees-not-linked-to-loan-are/EsZIrQ1Dc5A/">Case note : lender's fees not linked to loan are not interest income</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Case-note--lenders-fees-not-linked-to-loan-are/EsZIrQ1Dc5A/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Case-note--lenders-fees-not-linked-to-loan-are/EsZIrQ1Dc5A/">Case note : lender's fees not linked to loan are not interest income</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
