Tax treaty benefits denied where special tax measures and significant nonresident ownership reduce corporate tax under the protocol. The Protocol excludes the Icelandic social security charge 'Tryggingargjald' from taxes on total wages, treats interest integral to ship or aircraft operations as operational profits (excluding Article 11), conditions entitlement to dividends, interest, royalties and capital gains benefits on absence of special measures producing substantially lower tax and on ownership by nonresidents as determined after competent authority consultation, and allows a Contracting State to tax a foreign company's permanent establishment at a higher rate than similar domestic companies subject to a maximum rate difference.
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.
Tax treaty benefits denied where special tax measures and significant nonresident ownership reduce corporate tax under the protocol.
The Protocol excludes the Icelandic social security charge "Tryggingargjald" from taxes on total wages, treats interest integral to ship or aircraft operations as operational profits (excluding Article 11), conditions entitlement to dividends, interest, royalties and capital gains benefits on absence of special measures producing substantially lower tax and on ownership by nonresidents as determined after competent authority consultation, and allows a Contracting State to tax a foreign company's permanent establishment at a higher rate than similar domestic companies subject to a maximum rate difference.
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