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 ... Summary
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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