Non-discrimination: equal tax treatment for foreign nationals and enterprises, including permanent establishments and cross-border deductions. Article 24 forbids discriminatory taxation: nationals of one Contracting State must not face taxation or related requirements in the other State that are different or more burdensome than those applied to that State's own nationals. The Article requires that permanent establishments be taxed no less favorably than domestic enterprises carrying on similar activities, mandates equal conditions for deductibility of interest, royalties and similar payments (subject to specified exceptions), recognises parity for debts in determining taxable capital, and prohibits more burdensome treatment of enterprises owned or controlled by residents of the other State. These rules apply 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: equal tax treatment for foreign nationals and enterprises, including permanent establishments and cross-border deductions.
Article 24 forbids discriminatory taxation: nationals of one Contracting State must not face taxation or related requirements in the other State that are different or more burdensome than those applied to that State's own nationals. The Article requires that permanent establishments be taxed no less favorably than domestic enterprises carrying on similar activities, mandates equal conditions for deductibility of interest, royalties and similar payments (subject to specified exceptions), recognises parity for debts in determining taxable capital, and prohibits more burdensome treatment of enterprises owned or controlled by residents of the other State. These rules apply to taxes covered by the Agreement.
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