Non-discrimination: equal tax treatment for foreign nationals and enterprises, including permanent establishments and related deductions. Article 24 requires that nationals and persons in similar circumstances not be subjected to different or more burdensome taxation in the other Contracting State; permanent establishments of enterprises must be taxed no less favorably than domestic enterprises; cross-border interest, royalties and debts must be deductible on the same conditions as domestic equivalents; enterprises partly or wholly owned or controlled by residents of the other State must not face discriminatory taxation; the provision applies to taxes of every kind and description.
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 foreign nationals and enterprises, including permanent establishments and related deductions.
Article 24 requires that nationals and persons in similar circumstances not be subjected to different or more burdensome taxation in the other Contracting State; permanent establishments of enterprises must be taxed no less favorably than domestic enterprises; cross-border interest, royalties and debts must be deductible on the same conditions as domestic equivalents; enterprises partly or wholly owned or controlled by residents of the other State must not face discriminatory taxation; the provision applies to taxes of every kind and description.
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