Non-discrimination protections bar more burdensome taxation of foreign nationals and enterprises than domestic counterparts. Non-discrimination requires that nationals of one Contracting State not be subjected in the other Contracting State to taxation or related requirements that are different or more burdensome than those applied to that State's own nationals; permanent establishments must be taxed no less favourably than domestic enterprises; cross-border interest, royalties and similar payments are deductible on the same conditions as if paid to residents except where specific provisions apply; foreign-owned enterprises must not face more burdensome taxation; 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 protections bar more burdensome taxation of foreign nationals and enterprises than domestic counterparts.
Non-discrimination requires that nationals of one Contracting State not be subjected in the other Contracting State to taxation or related requirements that are different or more burdensome than those applied to that State's own nationals; permanent establishments must be taxed no less favourably than domestic enterprises; cross-border interest, royalties and similar payments are deductible on the same conditions as if paid to residents except where specific provisions apply; foreign-owned enterprises must not face more burdensome taxation; the Article applies to taxes of every kind and description.
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