Non-discrimination: equal tax treatment for nationals and enterprises under the DTAA, prohibiting more burdensome taxation. Non-discrimination prohibits more burdensome taxation or connected requirements on nationals of one Contracting State in the other State; permanent establishment taxation must not be less favourable for foreign enterprises carrying on the same activities; cross-border interest, royalties, fees for technical services and other disbursements shall be deductible under the same conditions as if paid to residents of the first-mentioned State except where specified treaty provisions apply; enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The Article applies to taxes of every kind and description.
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 nationals and enterprises under the DTAA, prohibiting more burdensome taxation.
Non-discrimination prohibits more burdensome taxation or connected requirements on nationals of one Contracting State in the other State; permanent establishment taxation must not be less favourable for foreign enterprises carrying on the same activities; cross-border interest, royalties, fees for technical services and other disbursements shall be deductible under the same conditions as if paid to residents of the first-mentioned State except where specified treaty provisions apply; enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The Article applies to taxes of every kind and description.
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