Non-discrimination in tax treatment: equal taxation and deductibility protections for foreign nationals and enterprises under the DTAA. Article 23 bars discriminatory taxation under the Finland DTAA by requiring that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to comparable nationals or enterprises. The rule covers permanent establishments, parity in deductibility of cross-border payments subject to specified exceptions, and equal treatment of enterprises with foreign ownership or control, while preserving exclusions for personal allowances and certain rate differentials.
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 treatment: equal taxation and deductibility protections for foreign nationals and enterprises under the DTAA.
Article 23 bars discriminatory taxation under the Finland DTAA by requiring that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to comparable nationals or enterprises. The rule covers permanent establishments, parity in deductibility of cross-border payments subject to specified exceptions, and equal treatment of enterprises with foreign ownership or control, while preserving exclusions for personal allowances and certain rate differentials.
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