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 ... Summary
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.
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