Non-discrimination in tax: equal treatment for nationals and enterprises across contracting states, subject to specific statutory exceptions. Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are other or more burdensome than those applied to nationals or similar enterprises in the same circumstances and conditions; it covers non-residents, treats taxation as taxes of every kind under the Agreement, ensures generally equal taxation of permanent establishments and controlled-capital enterprises, and preserves exceptions for higher rates on permanent establishment profits, Belgium's movable property prepayment on certain dividends, and resident-only personal allowances.
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 in tax: equal treatment for nationals and enterprises across contracting states, subject to specific statutory exceptions.
Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are other or more burdensome than those applied to nationals or similar enterprises in the same circumstances and conditions; it covers non-residents, treats taxation as taxes of every kind under the Agreement, ensures generally equal taxation of permanent establishments and controlled-capital enterprises, and preserves exceptions for higher rates on permanent establishment profits, Belgium's movable property prepayment on certain dividends, and resident-only personal allowances.
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