Non-discrimination in taxation secures equal tax treatment for nationals and enterprises across contracting states under the tax treaty. Non-discrimination ensures nationals of one Contracting State are not taxed or subjected to connected requirements more burdensome in the other State than nationals of that State in comparable circumstances; this protection also applies to non-residents. Permanent establishments of enterprises must receive tax treatment no less favourable than domestic enterprises, with a reservation on personal allowances; cross-border interest, royalties and similar payments are deductible on the same terms subject to specified exceptions; enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The provision applies to taxes covered by the Agreement.
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 taxation secures equal tax treatment for nationals and enterprises across contracting states under the tax treaty.
Non-discrimination ensures nationals of one Contracting State are not taxed or subjected to connected requirements more burdensome in the other State than nationals of that State in comparable circumstances; this protection also applies to non-residents. Permanent establishments of enterprises must receive tax treatment no less favourable than domestic enterprises, with a reservation on personal allowances; cross-border interest, royalties and similar payments are deductible on the same terms subject to specified exceptions; enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The provision applies to taxes covered by the Agreement.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
