Non-discrimination: equal tax treatment for foreign nationals and enterprises, with specified exceptions for allowances and certain payments. Article 25 requires non-discrimination in taxation: nationals and persons shall not face taxation or related requirements in the other State that are more burdensome than those applied to that State's own nationals in comparable circumstances. Permanent establishments of an enterprise must be taxed no less favourably than domestic enterprises, subject to exceptions for personal allowances and certain rate applications. Cross-border interest, royalties and debts are deductible under the same conditions as domestic counterparts, except where other treaty provisions apply, and enterprises owned or controlled by residents of the other State must not be taxed more onerously 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: equal tax treatment for foreign nationals and enterprises, with specified exceptions for allowances and certain payments.
Article 25 requires non-discrimination in taxation: nationals and persons shall not face taxation or related requirements in the other State that are more burdensome than those applied to that State's own nationals in comparable circumstances. Permanent establishments of an enterprise must be taxed no less favourably than domestic enterprises, subject to exceptions for personal allowances and certain rate applications. Cross-border interest, royalties and debts are deductible under the same conditions as domestic counterparts, except where other treaty provisions apply, and enterprises owned or controlled by residents of the other State must not be taxed more onerously than similar domestic enterprises.
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