Non-discrimination principle ensures equal tax treatment of nationals and enterprises across contracting states under the tax treaty. Non-discrimination prohibits a Contracting State from subjecting nationals of the other State to taxation or related requirements that are different or more burdensome than those applied to its own nationals in comparable circumstances, and extends to non-residents. Permanent establishments must not be taxed less favorably than domestic enterprises; cross-border interest, royalties and debts are to be deductible on the same conditions as domestic counterparts except where treaty exceptions apply; controlled enterprises must not face discriminatory taxation. 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 principle ensures equal tax treatment of nationals and enterprises across contracting states under the tax treaty.
Non-discrimination prohibits a Contracting State from subjecting nationals of the other State to taxation or related requirements that are different or more burdensome than those applied to its own nationals in comparable circumstances, and extends to non-residents. Permanent establishments must not be taxed less favorably than domestic enterprises; cross-border interest, royalties and debts are to be deductible on the same conditions as domestic counterparts except where treaty exceptions apply; controlled enterprises must not face discriminatory taxation. The Article covers taxes of every kind.
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