Non-discrimination in tax law ensures equal tax treatment for foreign nationals, enterprises, and cross-border payments. Non-discrimination requires that nationals and other persons of one Contracting State not face more burdensome taxation or connected requirements in the other State than comparable persons; this extends to non-residents. Permanent establishments must be taxed no less favourably than similar domestic enterprises, with exceptions preserving differential profit rates and exclusions for personal allowances. Cross-border interest, royalties and debts are deductible under the same conditions as domestic payments unless other Articles apply. Enterprises owned or controlled by residents of the other State must receive treatment no more burdensome than similar domestic enterprises.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Non-discrimination in tax law ensures equal tax treatment for foreign nationals, enterprises, and cross-border payments.
Non-discrimination requires that nationals and other persons of one Contracting State not face more burdensome taxation or connected requirements in the other State than comparable persons; this extends to non-residents. Permanent establishments must be taxed no less favourably than similar domestic enterprises, with exceptions preserving differential profit rates and exclusions for personal allowances. Cross-border interest, royalties and debts are deductible under the same conditions as domestic payments unless other Articles apply. Enterprises owned or controlled by residents of the other State must receive treatment no more burdensome than similar domestic enterprises.
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