Non-discrimination protects foreign nationals and enterprises from less favourable taxation under the Indonesia tax treaty. Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to that State's own nationals in comparable circumstances; this protection extends to non-residents. Permanent establishments and enterprises with foreign ownership must not be taxed less favourably than domestic counterparts, subject to an exception for personal allowances. Interest, royalties and similar payments between related cross-border enterprises are deductible under the same conditions as payments to residents, except where specified exceptions apply. 'Taxation' means 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 protects foreign nationals and enterprises from less favourable taxation under the Indonesia tax treaty.
Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to that State's own nationals in comparable circumstances; this protection extends to non-residents. Permanent establishments and enterprises with foreign ownership must not be taxed less favourably than domestic counterparts, subject to an exception for personal allowances. Interest, royalties and similar payments between related cross-border enterprises are deductible under the same conditions as payments to residents, except where specified exceptions apply. "Taxation" means the taxes covered by the Agreement.
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