Non-discrimination: equal tax treatment for nationals and enterprises across contracting states preventing discriminatory tax measures. Article 24 bars discriminatory taxation: nationals of one Contracting State must not face taxation or tax-related requirements in the other State that are different or more burdensome than those applied to that State's nationals in comparable circumstances, including non-residents. It requires that taxation of a permanent establishment not be less favorable than for domestic enterprises, preserves parity in deductibility of interest, royalties and similar payments except where other Articles provide otherwise, and protects enterprises owned or controlled by residents of the other State. The Article applies to 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: equal tax treatment for nationals and enterprises across contracting states preventing discriminatory tax measures.
Article 24 bars discriminatory taxation: nationals of one Contracting State must not face taxation or tax-related requirements in the other State that are different or more burdensome than those applied to that State's nationals in comparable circumstances, including non-residents. It requires that taxation of a permanent establishment not be less favorable than for domestic enterprises, preserves parity in deductibility of interest, royalties and similar payments except where other Articles provide otherwise, and protects enterprises owned or controlled by residents of the other State. The Article applies to taxes covered by the Agreement.
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