Non-discrimination in tax treaties ensures equal tax treatment and deductibility for comparable cross border transactions. Non-discrimination prevents one Contracting State from imposing taxation or related requirements that are different or more burdensome on nationals of the other State in comparable circumstances, extending to non-residents; it mandates equal treatment for taxes of every kind and requires that permanent establishment taxation, deductibility of cross-border interest and royalties, and treatment of enterprises with foreign ownership not be less favorable than that accorded to domestic counterparts, subject to specified treaty exceptions.
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 ensures equal tax treatment and deductibility for comparable cross border transactions.
Non-discrimination prevents one Contracting State from imposing taxation or related requirements that are different or more burdensome on nationals of the other State in comparable circumstances, extending to non-residents; it mandates equal treatment for taxes of every kind and requires that permanent establishment taxation, deductibility of cross-border interest and royalties, and treatment of enterprises with foreign ownership not be less favorable than that accorded to domestic counterparts, subject to specified treaty exceptions.
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