Non-discrimination: equal tax treatment for nationals, permanent establishments and cross-border deductions under the DTAA. Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or tax-related requirements that are different or more burdensome than those applied to comparable nationals or enterprises; permanent establishments must be taxed no less favourably than domestic enterprises, cross-border payments are deductible on the same conditions as domestic payments except as limited by specified articles, and ownership or control by residents of the other State must not create less favourable tax treatment. The provision covers taxes of every kind.
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, permanent establishments and cross-border deductions under the DTAA.
Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or tax-related requirements that are different or more burdensome than those applied to comparable nationals or enterprises; permanent establishments must be taxed no less favourably than domestic enterprises, cross-border payments are deductible on the same conditions as domestic payments except as limited by specified articles, and ownership or control by residents of the other State must not create less favourable tax treatment. The provision covers taxes of every kind.
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