Non-discrimination in tax treaties protects foreign nationals and enterprises from more burdensome taxation across contracting states. Article 25 mandates non-discrimination between nationals and protects persons who may be non-resident, requires that a permanent establishment be taxed no less favorably than domestic enterprises performing similar activities while allowing differences for personal allowances and certain company profit treatments, ensures deductible treatment of interest, royalties and debts between associated enterprises on equivalent conditions absent specified exceptions, prohibits discriminatory taxation of enterprises owned or controlled by residents of the other Contracting State, and 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 in tax treaties protects foreign nationals and enterprises from more burdensome taxation across contracting states.
Article 25 mandates non-discrimination between nationals and protects persons who may be non-resident, requires that a permanent establishment be taxed no less favorably than domestic enterprises performing similar activities while allowing differences for personal allowances and certain company profit treatments, ensures deductible treatment of interest, royalties and debts between associated enterprises on equivalent conditions absent specified exceptions, prohibits discriminatory taxation of enterprises owned or controlled by residents of the other Contracting State, and applies to taxes of every kind and description.
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