Non-discrimination ensures equal tax treatment for foreign nationals and enterprises, including permanent establishments and cross-border deductions. Nationals of one Contracting State must not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to that State's nationals in comparable circumstances; this extends to non-residents. Permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, with treaty-consistent exceptions. Enterprises partly or wholly owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. Interest, royalties and similar payments are deductible under the same conditions unless specified treaty paragraphs apply.
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 ensures equal tax treatment for foreign nationals and enterprises, including permanent establishments and cross-border deductions.
Nationals of one Contracting State must not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to that State's nationals in comparable circumstances; this extends to non-residents. Permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, with treaty-consistent exceptions. Enterprises partly or wholly owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. Interest, royalties and similar payments are deductible under the same conditions unless specified treaty paragraphs apply.
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