https://www.taxtmi.com/acts?id=51367 Items of other income beneficially owned by a resident and not covered by earlier articles are taxable only in that resident State, subject to exceptions: (a) guarantee fees arising in one State may be taxed there if beneficially owned by a connected resident who benefits from a special tax regime in its residence State; and (b) for the United States, guarantee fees paid by an expatriated entity and beneficially owned by a connected resident company may be taxed in the United States for a ten year period under specified limitations. If the beneficial owner carries on business in the other State through a permanent establishment and the income is effectively connected, Article 7 applies. en-us Wed, 21 May 2025 16:11:14 +0530 Wed, 21 May 2025 16:11:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51367 Items of other income beneficially owned by a resident and not covered by earlier articles are taxable only in that resident State, subject to exceptions: (a) guarantee fees arising in one State may be taxed there if beneficially owned by a connected resident who benefits from a special tax regime in its residence State; and (b) for the United States, guarantee fees paid by an expatriated entity and beneficially owned by a connected resident company may be taxed in the United States for a ten year period under specified limitations. If the beneficial owner carries on business in the other State through a permanent establishment and the income is effectively connected, Article 7 applies. Act-Rules DTAA Wed, 21 May 2025 16:11:14 +0530 https://www.taxtmi.com/acts?id=51367