Non-discrimination protections ensure equal tax treatment for comparable nationals and enterprises under the tax treaty. Non-discrimination protections require that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to comparable nationals or enterprises. Protections cover non-residents, permanent establishments (while excluding certain personal allowances), and enterprises with foreign ownership or control. Interest, royalties and similar payments made to residents of the other State are deductible under the same conditions as payments to domestic residents, subject to specified treaty exceptions. 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 protections ensure equal tax treatment for comparable nationals and enterprises under the tax treaty.
Non-discrimination protections require that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to comparable nationals or enterprises. Protections cover non-residents, permanent establishments (while excluding certain personal allowances), and enterprises with foreign ownership or control. Interest, royalties and similar payments made to residents of the other State are deductible under the same conditions as payments to domestic residents, subject to specified treaty exceptions. The Article applies to taxes covered by the Agreement.
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