Non-discrimination in taxation prevents more burdensome tax treatment of foreign nationals and enterprises across borders. Non-discrimination prevents nationals of one Contracting State from facing taxation or related requirements in the other State that are other or more burdensome than those applied to that State's own nationals in similar circumstances, covering non-residents as well. Enterprises and permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, though States need not extend personal allowances to non-residents and may apply higher rates to foreign permanent establishments; deductibility of cross-border interest, royalties and debts is to be on the same conditions as for residents except where specified treaty provisions provide otherwise. The Article applies to taxes of every kind.
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 prevents more burdensome tax treatment of foreign nationals and enterprises across borders.
Non-discrimination prevents nationals of one Contracting State from facing taxation or related requirements in the other State that are other or more burdensome than those applied to that State's own nationals in similar circumstances, covering non-residents as well. Enterprises and permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, though States need not extend personal allowances to non-residents and may apply higher rates to foreign permanent establishments; deductibility of cross-border interest, royalties and debts is to be on the same conditions as for residents except where specified treaty provisions provide otherwise. The Article applies to taxes of every kind.
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