Non-discrimination in taxation ensures equal tax and deduction treatment for foreign nationals and enterprises across treaty states. Non-discrimination requires nationals and certain non-residents not to face taxation or related requirements in the other Contracting State that are other or more burdensome than those applied to that State's own nationals; permanent establishments and enterprises with foreign ownership must receive no less favorable tax treatment than comparable domestic enterprises; cross-border interest, royalties and debts are deductible under the same conditions as domestic equivalents subject to specified treaty exceptions; these protections apply to the taxes covered by the Agreement.
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 equal tax and deduction treatment for foreign nationals and enterprises across treaty states.
Non-discrimination requires nationals and certain non-residents not to face taxation or related requirements in the other Contracting State that are other or more burdensome than those applied to that State's own nationals; permanent establishments and enterprises with foreign ownership must receive no less favorable tax treatment than comparable domestic enterprises; cross-border interest, royalties and debts are deductible under the same conditions as domestic equivalents subject to specified treaty exceptions; these protections apply to the taxes covered by the Agreement.
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