Non-discrimination in taxation prohibits more burdensome tax treatment of foreign nationals and enterprises under the treaty. The treaty requires that nationals and certain non-residents not face taxation or related requirements in the other Contracting State that are other or more burdensome than those applied to that State's nationals in comparable circumstances. It mandates equal treatment for permanent establishments and for enterprises with foreign ownership or control, allows deductibility of cross-border interest and royalties on the same conditions as domestic payments subject to specified exceptions, and limits applicability 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 in taxation prohibits more burdensome tax treatment of foreign nationals and enterprises under the treaty.
The treaty requires that nationals and certain non-residents not face taxation or related requirements in the other Contracting State that are other or more burdensome than those applied to that State's nationals in comparable circumstances. It mandates equal treatment for permanent establishments and for enterprises with foreign ownership or control, allows deductibility of cross-border interest and royalties on the same conditions as domestic payments subject to specified exceptions, and limits applicability to taxes covered by the Agreement.
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