Non-discrimination: taxpayers and permanent establishments must not face more burdensome taxation or related requirements under the treaty. Article 24 requires that nationals, stateless residents, enterprises and permanent establishments of one Contracting State shall not be subjected in the other Contracting State to taxation or connected requirements more burdensome than those applied to nationals or domestic enterprises in the same circumstances, particularly as to residence. Permanent establishments must be taxed no less favourably than domestic enterprises carrying on the same activities, subject to exceptions for domestic personal allowances and specified treaty provisions; cross-border interest, royalties and similar payments are deductible on the same terms as payments to residents when relevant.
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: taxpayers and permanent establishments must not face more burdensome taxation or related requirements under the treaty.
Article 24 requires that nationals, stateless residents, enterprises and permanent establishments of one Contracting State shall not be subjected in the other Contracting State to taxation or connected requirements more burdensome than those applied to nationals or domestic enterprises in the same circumstances, particularly as to residence. Permanent establishments must be taxed no less favourably than domestic enterprises carrying on the same activities, subject to exceptions for domestic personal allowances and specified treaty provisions; cross-border interest, royalties and similar payments are deductible on the same terms as payments to residents when relevant.
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