Non-discrimination ensures nationals and enterprises receive equal tax treatment in the other State, subject to specified exceptions. Article 24 prohibits subjecting nationals of one Contracting State to taxation or related requirements in the other State that are different or more burdensome than those applied to that State's own nationals; this extends to non-residents. It requires equal taxation for permanent establishments and permits a specified limited rate differential for companies of the other State. Interest, royalties and similar payments are to be deductible on the same conditions as if paid to domestic residents, subject to stated exceptions. Enterprises owned or controlled by non-resident residents must not be discriminated against, but personal allowances need not be granted to non-residents. The Article 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 ensures nationals and enterprises receive equal tax treatment in the other State, subject to specified exceptions.
Article 24 prohibits subjecting nationals of one Contracting State to taxation or related requirements in the other State that are different or more burdensome than those applied to that State's own nationals; this extends to non-residents. It requires equal taxation for permanent establishments and permits a specified limited rate differential for companies of the other State. Interest, royalties and similar payments are to be deductible on the same conditions as if paid to domestic residents, subject to stated exceptions. Enterprises owned or controlled by non-resident residents must not be discriminated against, but personal allowances need not be granted to non-residents. The Article covers taxes of every kind.
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