Non-discrimination ensures taxpayers and permanent establishments receive no more burdensome tax treatment than domestic counterparts. Non-discrimination protections require that nationals not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to nationals of that other State in comparable circumstances, and comparable parity protections extend to certain non-residents. Permanent establishments, deductible cross-border payments, and enterprises owned or controlled by residents of the other Contracting State must receive tax treatment no less favorable than domestic counterparts, subject to specified exceptions in other Articles; the Article applies 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 ensures taxpayers and permanent establishments receive no more burdensome tax treatment than domestic counterparts.
Non-discrimination protections require that nationals not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to nationals of that other State in comparable circumstances, and comparable parity protections extend to certain non-residents. Permanent establishments, deductible cross-border payments, and enterprises owned or controlled by residents of the other Contracting State must receive tax treatment no less favorable than domestic counterparts, subject to specified exceptions in other Articles; the Article applies to taxes covered by the Agreement.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
