Non-discrimination in tax treaties: equal tax treatment for nationals, permanent establishments, and cross-border payments. Non-discrimination prohibits differential taxation or related requirements against nationals and certain non-residents of a Contracting State, ensuring parity with domestic taxpayers. Permanent establishments of an enterprise shall not be taxed less favourably than domestic enterprises carrying on the same activities, with a capped tolerance for differences in tax rates; deductible payments to non-resident residents are to be allowed on the same conditions as if paid to domestic residents, subject to specified treaty exceptions. 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 in tax treaties: equal tax treatment for nationals, permanent establishments, and cross-border payments.
Non-discrimination prohibits differential taxation or related requirements against nationals and certain non-residents of a Contracting State, ensuring parity with domestic taxpayers. Permanent establishments of an enterprise shall not be taxed less favourably than domestic enterprises carrying on the same activities, with a capped tolerance for differences in tax rates; deductible payments to non-resident residents are to be allowed on the same conditions as if paid to domestic residents, subject to specified treaty exceptions. The Article applies to taxes of every kind and description.
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