Non-discrimination in taxation ensures equal treatment across treaty partners, with limited exceptions for permanent establishment rates. Article 24 requires that nationals and persons (including non-residents) of one Contracting State not be subjected in the other State to taxation or related requirements that are other or more burdensome than those applied to nationals of that other State; States need not grant personal allowances tied to civil status or family responsibilities to foreign residents. A permanent establishment of an enterprise must not be taxed less favorably than domestic enterprises, subject to a permitted deviation allowing up to a ten percentage point higher tax rate on profits of a foreign company's permanent establishment; interest, royalties and other disbursements are deductible on the same conditions as if paid to residents, unless specified treaty provisions apply, and equity-owned enterprises controlled by residents of the other State must receive no more burdensome taxation. The Article covers 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 in taxation ensures equal treatment across treaty partners, with limited exceptions for permanent establishment rates.
Article 24 requires that nationals and persons (including non-residents) of one Contracting State not be subjected in the other State to taxation or related requirements that are other or more burdensome than those applied to nationals of that other State; States need not grant personal allowances tied to civil status or family responsibilities to foreign residents. A permanent establishment of an enterprise must not be taxed less favorably than domestic enterprises, subject to a permitted deviation allowing up to a ten percentage point higher tax rate on profits of a foreign company's permanent establishment; interest, royalties and other disbursements are deductible on the same conditions as if paid to residents, unless specified treaty provisions apply, and equity-owned enterprises controlled by residents of the other State must receive no more burdensome taxation. The Article covers taxes of every kind and description.
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