Non-discrimination protects nationals and enterprises from differential cross-border taxation and ensures equal tax deductibility. Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements more burdensome than those applicable to that State's nationals in comparable circumstances, and extends to non-residents. Permanent establishments and enterprises owned or controlled by residents of the other State must receive no less favourable taxation than domestic enterprises; cross-border interest, royalties and similar payments are deductible on the same conditions as if paid to a domestic resident, subject to specific treaty exceptions. The Article covers 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 protects nationals and enterprises from differential cross-border taxation and ensures equal tax deductibility.
Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements more burdensome than those applicable to that State's nationals in comparable circumstances, and extends to non-residents. Permanent establishments and enterprises owned or controlled by residents of the other State must receive no less favourable taxation than domestic enterprises; cross-border interest, royalties and similar payments are deductible on the same conditions as if paid to a domestic resident, subject to specific treaty exceptions. The Article covers taxes of every kind and description.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
