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Non-discrimination in tax treaties: equal tax treatment for nationals, permanent establishments, and cross-border deductions. Non-discrimination requires that nationals and non-residents not be subjected in the other Contracting State to taxation or connected requirements that are other or more burdensome than those applied to that State's nationals in the same circumstances. Permanent establishments must not be taxed less favourably than local enterprises undertaking the same activities, with specified exceptions. Cross border interest, royalties and similar payments and debts are deductible on the same conditions as if paid to residents except where treaty provisions provide otherwise. Enterprises owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. The Article covers taxes of every kind.
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 deductions.
Non-discrimination requires that nationals and non-residents not be subjected in the other Contracting State to taxation or connected requirements that are other or more burdensome than those applied to that State's nationals in the same circumstances. Permanent establishments must not be taxed less favourably than local enterprises undertaking the same activities, with specified exceptions. Cross border interest, royalties and similar payments and debts are deductible on the same conditions as if paid to residents except where treaty provisions provide otherwise. Enterprises owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. The Article covers taxes of every kind.
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