Non-discrimination: tax treatment must not be more burdensome for nationals or enterprises of the other Contracting State. Article 24 prohibits tax measures in one Contracting State that are other or more burdensome than those applied to nationals or similar enterprises of that State, extending this protection to non-residents. It requires that permanent establishment taxation be no less favourable than for domestic enterprises, subject to allowances and Article 7(3); mandates equal deductibility conditions for interest, royalties and debts between cross border enterprises except where treaty exceptions apply; and forbids more burdensome taxation of enterprises owned or controlled by residents of the other State. The Article applies to taxes of every kind and description.
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: tax treatment must not be more burdensome for nationals or enterprises of the other Contracting State.
Article 24 prohibits tax measures in one Contracting State that are other or more burdensome than those applied to nationals or similar enterprises of that State, extending this protection to non-residents. It requires that permanent establishment taxation be no less favourable than for domestic enterprises, subject to allowances and Article 7(3); mandates equal deductibility conditions for interest, royalties and debts between cross border enterprises except where treaty exceptions apply; and forbids more burdensome taxation of enterprises owned or controlled by residents of the other State. The Article applies to taxes of every kind and description.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
AI OCR ✕
of 
TaxTMI 
TaxTMI 
