Non-discrimination protects cross-border persons and enterprises from more burdensome taxation in the other contracting state. Non-discrimination requires that persons with right of abode, incorporation, or nationality in one Contracting Party not be subjected in the other Party to taxation or related requirements that are other or more burdensome than those applied to comparable persons there; this protection also covers non-residents. Taxation of a permanent establishment must not be less favourably levied than on domestic enterprises with similar activities, subject to specified exceptions; payments such as interest, royalties and technical service fees paid to residents of the other Party are deductible under the same conditions as if paid to residents of the payer's Party, and enterprises controlled by residents of the other Party must not face more burdensome tax treatment than similar domestic enterprises.
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 cross-border persons and enterprises from more burdensome taxation in the other contracting state.
Non-discrimination requires that persons with right of abode, incorporation, or nationality in one Contracting Party not be subjected in the other Party to taxation or related requirements that are other or more burdensome than those applied to comparable persons there; this protection also covers non-residents. Taxation of a permanent establishment must not be less favourably levied than on domestic enterprises with similar activities, subject to specified exceptions; payments such as interest, royalties and technical service fees paid to residents of the other Party are deductible under the same conditions as if paid to residents of the payer's Party, and enterprises controlled by residents of the other Party must not face more burdensome tax treatment than similar domestic enterprises.
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