Non-discrimination in tax treaties ensures nationals and like enterprises face no more burdensome taxation than locals. Non-discrimination prohibits a Contracting State from imposing taxation or connected requirements on nationals of the other State that are different or more burdensome than those applied to its own nationals in the same circumstances, subject to no obligation to grant resident-only personal allowances to non-residents. Taxation of a permanent establishment must not be less favourable than for comparable domestic enterprises, and enterprises owned or controlled by residents of the other State must not face more burdensome taxation than similar domestic enterprises; 'taxation' means the taxes covered by the Convention.
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 nationals and like enterprises face no more burdensome taxation than locals.
Non-discrimination prohibits a Contracting State from imposing taxation or connected requirements on nationals of the other State that are different or more burdensome than those applied to its own nationals in the same circumstances, subject to no obligation to grant resident-only personal allowances to non-residents. Taxation of a permanent establishment must not be less favourable than for comparable domestic enterprises, and enterprises owned or controlled by residents of the other State must not face more burdensome taxation than similar domestic enterprises; "taxation" means the taxes covered by the Convention.
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