Non-discrimination in taxation: ensures foreign nationals and enterprises face no more burdensome tax treatment than domestic counterparts. Nationals and other persons shall not be subjected in the other Contracting State to taxation or related requirements that are different or more burdensome than those applied to nationals in comparable circumstances. Permanent establishments must not be taxed less favorably than domestic enterprises engaged in the same activities, subject to allowances, rate differences and Article 7(3). Interest, royalties and other disbursements are deductible under the same conditions as if paid to residents, except where specific provisions apply; related-party ownership must not attract discriminatory taxation. The Article covers the taxes in Article 2.
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 taxation: ensures foreign nationals and enterprises face no more burdensome tax treatment than domestic counterparts.
Nationals and other persons shall not be subjected in the other Contracting State to taxation or related requirements that are different or more burdensome than those applied to nationals in comparable circumstances. Permanent establishments must not be taxed less favorably than domestic enterprises engaged in the same activities, subject to allowances, rate differences and Article 7(3). Interest, royalties and other disbursements are deductible under the same conditions as if paid to residents, except where specific provisions apply; related-party ownership must not attract discriminatory taxation. The Article covers the taxes in Article 2.
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