Non-discrimination principle ensures foreign nationals and enterprises are not taxed more burdensomely than comparable local persons or entities. Non-discrimination requires that nationals and enterprises of one territory not be subjected in the other territory to taxation or connected requirements that are other or more burdensome than those applicable to nationals or similar enterprises of that other territory; parity extends to residence-related treatment, permanent establishment taxation parity (with limited exceptions for personal allowances and specific treaty provisions), equivalent deductibility of cross-border interest and royalties except where other treaty paragraphs apply, and equal treatment where ownership or control by nonresidents exists, for 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 principle ensures foreign nationals and enterprises are not taxed more burdensomely than comparable local persons or entities.
Non-discrimination requires that nationals and enterprises of one territory not be subjected in the other territory to taxation or connected requirements that are other or more burdensome than those applicable to nationals or similar enterprises of that other territory; parity extends to residence-related treatment, permanent establishment taxation parity (with limited exceptions for personal allowances and specific treaty provisions), equivalent deductibility of cross-border interest and royalties except where other treaty paragraphs apply, and equal treatment where ownership or control by nonresidents exists, for taxes covered by the agreement.
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